Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
TP Adjustment - Comparable selection - determination of arm’s length prices (ALP) - The High Court observed that the dissimilarity in products sold and their respective turnovers could significantly impact the profitability of an entity. Despite acknowledging significant differences and accepting the appellant's arguments, the ITAT failed to entirely exclude Modicare. The Court considered this a vital infirmity and directed the ITAT to re-examine the appropriateness of including Modicare and the functional difference in marketing strategy between the entities.
TP Adjustment - Comparable selection - determination of arm’s length prices (ALP) - The High Court observed that the dissimilarity in products sold and their respective turnovers could significantly impact the profitability of an entity. Despite acknowledging significant differences and accepting the appellant's arguments, the ITAT failed to entirely exclude Modicare. The Court considered this a vital infirmity and directed the ITAT to re-examine the appropriateness of including Modicare and the functional difference in marketing strategy between the entities.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
