Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
ALP of the international transaction of payment of Fees for Management services - 5% mark-up under Cost plus method - Even if, we proceed with the assumption that the mark up of 5% is not at ALP, which should be as low as 1% or even less than that, still the difference arising on account of such mark-up going even up to 0% in a comparable uncontrolled situation, would be within +/-5% range, not requiring any TP adjustment
ALP of the international transaction of payment of Fees for Management services - 5% mark-up under Cost plus method - Even if, we proceed with the assumption that the mark up of 5% is not at ALP, which should be as low as 1% or even less than that, still the difference arising on account of such mark-up going even up to 0% in a comparable uncontrolled situation, would be within +/-5% range, not requiring any TP adjustment
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
Join Channel 
