Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Business dependence on regulatory affairs and compliance processes established an associated-enterprise relationship, which was sustained because the relationship had also been accepted in transfer-pricing documentation. Foreign associated-enterprise selection as the tested party was rejected where reliable foreign comparable data was not readily accessible and geographical and economic conditions differed; the assessee was retained as the tested party. Domain-specific regulatory affairs services were not treated as KPO services merely by reference to the Rule 10TA definition, and comparables from diverse R&D, engineering, IT, advertising and gaming activities were unsuitable. Fresh benchmarking and comparable selection were directed in line with the assessee's FAR profile after a hearing opportunity.
Business dependence on regulatory affairs and compliance processes established an associated-enterprise relationship, which was sustained because the relationship had also been accepted in transfer-pricing documentation. Foreign associated-enterprise selection as the tested party was rejected where reliable foreign comparable data was not readily accessible and geographical and economic conditions differed; the assessee was retained as the tested party. Domain-specific regulatory affairs services were not treated as KPO services merely by reference to the Rule 10TA definition, and comparables from diverse R&D, engineering, IT, advertising and gaming activities were unsuitable. Fresh benchmarking and comparable selection were directed in line with the assessee's FAR profile after a hearing opportunity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
