Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT
TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT
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