Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Segmentation of business for transfer pricing was held determinative: the tribunal accepted the assessee's segmental accounts and prior-year coordinate-bench finding that two distinct segments exist (AMC services; agency/marketing support), and concluded the TPO should not aggregate them for TNMM benchmarking without fresh verification. The tribunal noted provided bases for allocation of common expenses and that lack of audit alone does not invalidate segmental accounts. Matter remitted to TPO for limited verification of segmental accounts, comparable selection and computation of PLI, with opportunity to be heard; if segmental PLIs fall within tolerance, no adjustment follows.
Segmentation of business for transfer pricing was held determinative: the tribunal accepted the assessee's segmental accounts and prior-year coordinate-bench finding that two distinct segments exist (AMC services; agency/marketing support), and concluded the TPO should not aggregate them for TNMM benchmarking without fresh verification. The tribunal noted provided bases for allocation of common expenses and that lack of audit alone does not invalidate segmental accounts. Matter remitted to TPO for limited verification of segmental accounts, comparable selection and computation of PLI, with opportunity to be heard; if segmental PLIs fall within tolerance, no adjustment follows.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
