Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
In transfer pricing for captive software development services, high turnover comparables were excluded because a wide turnover gap distorts economies of scale, brand value, market positioning and risk profile; entities with turnover above 200 crore were therefore removed and the arm's length price recomputed. Companies with diversified or specialised functions outside captive software development were also excluded as functionally dissimilar, leading to fresh computation of the profit level indicator and ALP. For delayed foreign currency trade receivables, SBI PLR was rejected as an inappropriate domestic benchmark, and LIBOR plus 200 basis points was applied after allowing the agreed or standard credit period for recomputation of the adjustment.
In transfer pricing for captive software development services, high turnover comparables were excluded because a wide turnover gap distorts economies of scale, brand value, market positioning and risk profile; entities with turnover above 200 crore were therefore removed and the arm's length price recomputed. Companies with diversified or specialised functions outside captive software development were also excluded as functionally dissimilar, leading to fresh computation of the profit level indicator and ALP. For delayed foreign currency trade receivables, SBI PLR was rejected as an inappropriate domestic benchmark, and LIBOR plus 200 basis points was applied after allowing the agreed or standard credit period for recomputation of the adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
