Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
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