Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
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TP adjustment - application of the Resale Price Method (RPM) as the Most Appropriate Method (‘MAM’) - trading activity - The decision of Supreme Court in Kedarnath Jute Manufacturing Co. Ltd.[1965 (4) TMI 91 - SUPREME COURT] is an authority for the proposition that tax authorities and adjudications as well as assessee are not precluded by the positions taken in returns, documents or accounts and have the duty (and a corresponding right) to apply the correct legal principle. Thus, the use of one method in a transfer pricing report does not estop the assessee from later claiming that another method is the most appropriate one, provided that is indeed the correct position. - HC
TP adjustment - application of the Resale Price Method (RPM) as the Most Appropriate Method (‘MAM’) - trading activity - The decision of Supreme Court in Kedarnath Jute Manufacturing Co. Ltd.[1965 (4) TMI 91 - SUPREME COURT] is an authority for the proposition that tax authorities and adjudications as well as assessee are not precluded by the positions taken in returns, documents or accounts and have the duty (and a corresponding right) to apply the correct legal principle. Thus, the use of one method in a transfer pricing report does not estop the assessee from later claiming that another method is the most appropriate one, provided that is indeed the correct position. - HC
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