Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Cost Plus Method based on an internal comparable was treated as the most appropriate method for software development services where identical services were supplied to an independent entity at the same cost-plus mark-up. A traditional pricing method cannot be replaced by a transactional profit method without cogent reasons demonstrating its inadequacy, including proper consideration of the functions, assets and risks analysis. The services were at arm's length and the transfer-pricing adjustment was deleted. No interest adjustment arose on delayed associated-enterprise receivables because interest was not charged on comparable delayed payments by unrelated parties; that adjustment was also deleted.
Cost Plus Method based on an internal comparable was treated as the most appropriate method for software development services where identical services were supplied to an independent entity at the same cost-plus mark-up. A traditional pricing method cannot be replaced by a transactional profit method without cogent reasons demonstrating its inadequacy, including proper consideration of the functions, assets and risks analysis. The services were at arm's length and the transfer-pricing adjustment was deleted. No interest adjustment arose on delayed associated-enterprise receivables because interest was not charged on comparable delayed payments by unrelated parties; that adjustment was also deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
