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...
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 
of 4929 
