Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Telecommunication-business tax treatment covers the timing and scope of deductions, revenue expenditure and transfer-pricing adjustments. Profits eligible for the telecommunication undertaking deduction include receipts with an integral business nexus, while Service from India Scheme incentives are excluded; the initial deduction year depends on when the claim was actually allowed. Annual telecom licence fees are subject to statutory amortisation rather than revenue deduction, whereas spectrum-use charges, ordinary advertising costs, subscriber-fraud losses and certain asset-restoration costs may be revenue expenditure. Automated domestic roaming payments and pre-paid distributor discounts do not require tax deduction at source. Brand-royalty and advertisement, marketing and promotion adjustments cannot rest on commercial-necessity objections or the bright-line test without a demonstrable international transaction.
Telecommunication-business tax treatment covers the timing and scope of deductions, revenue expenditure and transfer-pricing adjustments. Profits eligible for the telecommunication undertaking deduction include receipts with an integral business nexus, while Service from India Scheme incentives are excluded; the initial deduction year depends on when the claim was actually allowed. Annual telecom licence fees are subject to statutory amortisation rather than revenue deduction, whereas spectrum-use charges, ordinary advertising costs, subscriber-fraud losses and certain asset-restoration costs may be revenue expenditure. Automated domestic roaming payments and pre-paid distributor discounts do not require tax deduction at source. Brand-royalty and advertisement, marketing and promotion adjustments cannot rest on commercial-necessity objections or the bright-line test without a demonstrable international transaction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
