Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.
TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
