Mis-declaration and Concealment: confiscation affirmed, transaction value re-determined and mandatory penalty sustained; redemption allowed on payment...
Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
