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...
TP adjustment - Direction in remand proceeding - Customs Duty Adjustment, Air Freight Adjustment and Foreign Exchange Adjustment - If the Tribunal has fixed how such adjustments have to be made or not to be made. This hardly leaves any discretion to deal with these issues afresh with the TPO.
TP adjustment - Direction in remand proceeding - Customs Duty Adjustment, Air Freight Adjustment and Foreign Exchange Adjustment - If the Tribunal has fixed how such adjustments have to be made or not to be made. This hardly leaves any discretion to deal with these issues afresh with the TPO.
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