Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
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