Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.
Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
