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...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
TNMM comparability under transfer pricing was applied across operating expenses, software services, ITeS, distribution and manufacturing segments, with the Tribunal treating provision for doubtful debts and routine rates and taxes as operating items, revising the comparable sets on functional similarity and turnover filters, and directing gross-margin benchmarking for the distribution segment. It held that working capital differences require adjustment under TNMM and remitted quantification for fresh computation. Delayed receivables were not sustained as a notional interest adjustment on the facts, and the royalty and intra-group service payments were accepted as closely linked business transactions that could not be benchmarked at nil without proper comparability analysis. The disallowance under section 40(a)(ia) was also deleted for lack of proof of TDS liability.
TNMM comparability under transfer pricing was applied across operating expenses, software services, ITeS, distribution and manufacturing segments, with the Tribunal treating provision for doubtful debts and routine rates and taxes as operating items, revising the comparable sets on functional similarity and turnover filters, and directing gross-margin benchmarking for the distribution segment. It held that working capital differences require adjustment under TNMM and remitted quantification for fresh computation. Delayed receivables were not sustained as a notional interest adjustment on the facts, and the royalty and intra-group service payments were accepted as closely linked business transactions that could not be benchmarked at nil without proper comparability analysis. The disallowance under section 40(a)(ia) was also deleted for lack of proof of TDS liability.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
