Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Transfer-pricing comparability under TNMM requires a FAR analysis; company size may support a turnover filter, excluding high-turnover entities when determining arm's length remuneration for software development services. Where depreciation materially differs because of asset types, technology or investment levels, a cash profit level indicator excluding depreciation may compare real margins. Provision for bad and doubtful debts remains operating expenditure unless extraordinary. Free-use testing equipment supplied by an associated enterprise does not create a taxable business perquisite where ownership remains with the enterprise, no depreciation is claimed, and use is confined to testing software for it.
Transfer-pricing comparability under TNMM requires a FAR analysis; company size may support a turnover filter, excluding high-turnover entities when determining arm's length remuneration for software development services. Where depreciation materially differs because of asset types, technology or investment levels, a cash profit level indicator excluding depreciation may compare real margins. Provision for bad and doubtful debts remains operating expenditure unless extraordinary. Free-use testing equipment supplied by an associated enterprise does not create a taxable business perquisite where ownership remains with the enterprise, no depreciation is claimed, and use is confined to testing software for it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
