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...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as deemed international transaction and accordingly cannot be included for the purpose of ALP adjustment. TPO is directed accordingly to consider only the transaction with AE for the purpose of determination ALP - AT
TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as deemed international transaction and accordingly cannot be included for the purpose of ALP adjustment. TPO is directed accordingly to consider only the transaction with AE for the purpose of determination ALP - AT
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