Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Treat excess slump-sale consideration over identifiable tangible asset values as goodwill or commercial rights and allow depreciation thereon under section 32(1)(ii); adopt the Departmental Valuation Officer's fair market values for land, building and other tangible assets when computing depreciation and direct the Assessing Officer to recompute accordingly. Reject attributing the entire balance to land or limiting depreciation to transferor WDV where valuation shows a balancing figure. Verify claims for depreciation on landscaping and internal roads with opportunity to the taxpayer before adjudication.
Treat excess slump-sale consideration over identifiable tangible asset values as goodwill or commercial rights and allow depreciation thereon under section 32(1)(ii); adopt the Departmental Valuation Officer's fair market values for land, building and other tangible assets when computing depreciation and direct the Assessing Officer to recompute accordingly. Reject attributing the entire balance to land or limiting depreciation to transferor WDV where valuation shows a balancing figure. Verify claims for depreciation on landscaping and internal roads with opportunity to the taxpayer before adjudication.
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