Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices.
TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices.
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