Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared
TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared
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