Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The Appellate Tribunal addressed various Transfer Pricing (TP) issues. Regarding software services, the Tribunal upheld the selection of comparables by the assessee over the Transfer Pricing Officer's choices. The Tribunal also adjusted rates for guarantees provided to AEs based on performance and financial aspects. For inter-company loans, the Tribunal questioned the characterization as loans without considering the quasi-equity nature argued by the assessee. The Tribunal dismissed a claim for brand royalty fees, affirming that the brand is not owned by the assessee, hence no royalty is applicable.
The Appellate Tribunal addressed various Transfer Pricing (TP) issues. Regarding software services, the Tribunal upheld the selection of comparables by the assessee over the Transfer Pricing Officer's choices. The Tribunal also adjusted rates for guarantees provided to AEs based on performance and financial aspects. For inter-company loans, the Tribunal questioned the characterization as loans without considering the quasi-equity nature argued by the assessee. The Tribunal dismissed a claim for brand royalty fees, affirming that the brand is not owned by the assessee, hence no royalty is applicable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
