TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TP adjustment for corporate guarantee commission at 0.50% on guaranteed amount directed. Interest on receivables beyond agreed credit period of 60-240 days for non-AEs to be allowed for AEs. Interest rate on foreign currency receivables/advances accepted as LIBOR+200 points. Weighted deduction u/s 35(2AB) for clinical trial expenses incurred outside approved R&D facilities allowed based on prescribed authority approval and judicial precedents.
TP adjustment for corporate guarantee commission at 0.50% on guaranteed amount directed. Interest on receivables beyond agreed credit period of 60-240 days for non-AEs to be allowed for AEs. Interest rate on foreign currency receivables/advances accepted as LIBOR+200 points. Weighted deduction u/s 35(2AB) for clinical trial expenses incurred outside approved R&D facilities allowed based on prescribed authority approval and judicial precedents.
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