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...
Transfer-pricing reference to the TPO for CCD interest requires actual non-disclosure of the relevant international transaction in Form 3CEB where selection occurred on non-transfer-pricing risk parameters. Form 3CEB identification and quantification of the CCD interest transaction satisfied that disclosure condition; differences between accounting and tax figures did not establish an unreported transaction. Notices, objections and approval could not cure failure of the substantive reference condition. The resulting transfer-pricing adjustment was deleted, while CCD characterisation, benchmarking and interest-deduction merits remained undecided and consequential tax and statutory interest required recomputation.
Transfer-pricing reference to the TPO for CCD interest requires actual non-disclosure of the relevant international transaction in Form 3CEB where selection occurred on non-transfer-pricing risk parameters. Form 3CEB identification and quantification of the CCD interest transaction satisfied that disclosure condition; differences between accounting and tax figures did not establish an unreported transaction. Notices, objections and approval could not cure failure of the substantive reference condition. The resulting transfer-pricing adjustment was deleted, while CCD characterisation, benchmarking and interest-deduction merits remained undecided and consequential tax and statutory interest required recomputation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
