Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
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Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
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