Brokerage commission benchmarking and investment advisory comparability depend on functional differences, economic circumstances and the services prov...
For the relevant assessment, clause (aa) of Explanation 2 to section 139(1) prescribed 30 November as the return-filing deadline where a transfer pricing report was required under section 92E. A return filed before that deadline was timely for set-off of current-year and brought-forward business losses, in accordance with law. The Assessing Officer could not depart from the draft assessment without giving the taxpayer a hearing. Interest-free working-capital support claimed to have been incorrectly recorded as reimbursement required corroboration from the parent, an attested bank statement and auditor certification. An unpaid laptop reimbursement would not generate a payment entry in the taxpayer's bank account; the parent's procurement role required confirmation of supply and the reimbursement claim.
For the relevant assessment, clause (aa) of Explanation 2 to section 139(1) prescribed 30 November as the return-filing deadline where a transfer pricing report was required under section 92E. A return filed before that deadline was timely for set-off of current-year and brought-forward business losses, in accordance with law. The Assessing Officer could not depart from the draft assessment without giving the taxpayer a hearing. Interest-free working-capital support claimed to have been incorrectly recorded as reimbursement required corroboration from the parent, an attested bank statement and auditor certification. An unpaid laptop reimbursement would not generate a payment entry in the taxpayer's bank account; the parent's procurement role required confirmation of supply and the reimbursement claim.
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