Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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.
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