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...
Rule 10CA(5) treats an actual royalty rate within the arm's-length range as the arm's-length price; the median applies only when the transaction falls outside that range. Intra-group IT, business-support and administrative services require assessment of need, actual rendition, commercial benefit, duplication and shareholder activity, supported by contemporaneous operational records and rational allocation keys. A nil valuation under the Other Method requires objective pricing material rather than rejection of TNMM alone. Transfer-pricing and business-expenditure enquiries remain distinct: genuine services with a direct business nexus cannot be disallowed merely because their benefit is questioned, absent capital, personal, prohibited or extraneous expenditure. The royalty, service-pricing and alternative business-expenditure adjustments were deleted.
Rule 10CA(5) treats an actual royalty rate within the arm's-length range as the arm's-length price; the median applies only when the transaction falls outside that range. Intra-group IT, business-support and administrative services require assessment of need, actual rendition, commercial benefit, duplication and shareholder activity, supported by contemporaneous operational records and rational allocation keys. A nil valuation under the Other Method requires objective pricing material rather than rejection of TNMM alone. Transfer-pricing and business-expenditure enquiries remain distinct: genuine services with a direct business nexus cannot be disallowed merely because their benefit is questioned, absent capital, personal, prohibited or extraneous expenditure. The royalty, service-pricing and alternative business-expenditure adjustments were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
