Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
For specified domestic transactions, market value constitutes the arm's length price, with the special rule in the Explanation to section 80A(6) prevailing over the general provision. Regulated tariffs at which generating companies supply distribution licensees are not comparable uncontrolled prices because they are not negotiated in uncontrolled conditions. The cement unit's purchase rate from its distribution licensee was the more reliable internal comparable for captive electricity transfers; functional differences did not alter that comparison, and a mark-up on an average price was unsustainable. The transfer-pricing adjustment was deleted and the related deduction allowed. A challenge solely to initiation of penalty proceedings was dismissed as premature.
For specified domestic transactions, market value constitutes the arm's length price, with the special rule in the Explanation to section 80A(6) prevailing over the general provision. Regulated tariffs at which generating companies supply distribution licensees are not comparable uncontrolled prices because they are not negotiated in uncontrolled conditions. The cement unit's purchase rate from its distribution licensee was the more reliable internal comparable for captive electricity transfers; functional differences did not alter that comparison, and a mark-up on an average price was unsustainable. The transfer-pricing adjustment was deleted and the related deduction allowed. A challenge solely to initiation of penalty proceedings was dismissed as premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4927 
