TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Taxation rights for the salary earned for work done in the USA - India USA DTAA - the situs of accrual is the situs of services rendered which in the instant case is clearly in the USA and the amounts are also received in the USA. Hence, it cannot form part of income taxable in India as per Section 5 - AT
Taxation rights for the salary earned for work done in the USA - India USA DTAA - the situs of accrual is the situs of services rendered which in the instant case is clearly in the USA and the amounts are also received in the USA. Hence, it cannot form part of income taxable in India as per Section 5 - AT
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