Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
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The government notifies that for assessment year 2025-26 an international or specified domestic transaction's actual price will be deemed the arm's-length price if the difference between the arm's-length price under section 92C and the actual transaction price does not exceed 1% of the actual price for wholesale trading and 3% for all other cases. Wholesale trading is defined by (a) finished goods purchase cost ≥80% of total trading costs and (b) average monthly closing inventory ≤10% of related sales. The explanatory memorandum states the tolerance ranges and that no one will be adversely affected by retrospective application.
The government notifies that for assessment year 2025-26 an international or specified domestic transaction's actual price will be deemed the arm's-length price if the difference between the arm's-length price under section 92C and the actual transaction price does not exceed 1% of the actual price for wholesale trading and 3% for all other cases. Wholesale trading is defined by (a) finished goods purchase cost ≥80% of total trading costs and (b) average monthly closing inventory ≤10% of related sales. The explanatory memorandum states the tolerance ranges and that no one will be adversely affected by retrospective application.
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