Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
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