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...
Supply of services or not? - third party software - The approach of commissioner while dealing with the issues is in accordance with the international practices of treatment of the software related transactions. Thus the order of the Commissioner holding that these services are classifiable under the category of ‘Information Technology Software Services’ after 16.05.2008 and prior to that under the category of ‘Intellectual Proper Services’ cannot be faulted with.
Supply of services or not? - third party software - The approach of commissioner while dealing with the issues is in accordance with the international practices of treatment of the software related transactions. Thus the order of the Commissioner holding that these services are classifiable under the category of ‘Information Technology Software Services’ after 16.05.2008 and prior to that under the category of ‘Intellectual Proper Services’ cannot be faulted with.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
