TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Co-terminus appellate powers require full verification before deleting TDS disallowances for alleged non-deduction of tax on freight-forwarding paymen...
Settlement agreements and agreements to sell must be read together to determine whether an admitted operational debt has been discharged or merely secured. Where payment of outstanding dues remains an option that cancels the proposed sale, and no consideration or possession has passed, the debt retains its operational character. A property-related specific-performance dispute does not constitute a pre-existing dispute over supplied goods where liability is acknowledged and no quality or quantity objection is documented. Novation requires a mutually agreed replacement or extinction of the original obligation; contingent sale terms that preserve payment liability do not satisfy that requirement.
Settlement agreements and agreements to sell must be read together to determine whether an admitted operational debt has been discharged or merely secured. Where payment of outstanding dues remains an option that cancels the proposed sale, and no consideration or possession has passed, the debt retains its operational character. A property-related specific-performance dispute does not constitute a pre-existing dispute over supplied goods where liability is acknowledged and no quality or quantity objection is documented. Novation requires a mutually agreed replacement or extinction of the original obligation; contingent sale terms that preserve payment liability do not satisfy that requirement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4932 
