Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Under TNMM, the comparable set in a transfer-pricing study is not conclusive and may be revised during proceedings; functional comparability depends on functions performed, assets employed and risks assumed. A manufacturing entity was treated as incomparable to a medical-device trader undertaking related research and development activities, requiring recomputation of the arm's length margin. No notional-interest adjustment was warranted on an interest-free loan to an associated enterprise where the advance was commercially expedient in the context of goods sales, on the stated facts. A challenge to proposed penalty proceedings was premature, while an alleged double disallowance required document-based verification before relief.
Under TNMM, the comparable set in a transfer-pricing study is not conclusive and may be revised during proceedings; functional comparability depends on functions performed, assets employed and risks assumed. A manufacturing entity was treated as incomparable to a medical-device trader undertaking related research and development activities, requiring recomputation of the arm's length margin. No notional-interest adjustment was warranted on an interest-free loan to an associated enterprise where the advance was commercially expedient in the context of goods sales, on the stated facts. A challenge to proposed penalty proceedings was premature, while an alleged double disallowance required document-based verification before relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
