Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
Transfer-pricing comparability under TNMM requires a FAR analysis; company size may support a turnover filter, excluding high-turnover entities when determining arm's length remuneration for software development services. Where depreciation materially differs because of asset types, technology or investment levels, a cash profit level indicator excluding depreciation may compare real margins. Provision for bad and doubtful debts remains operating expenditure unless extraordinary. Free-use testing equipment supplied by an associated enterprise does not create a taxable business perquisite where ownership remains with the enterprise, no depreciation is claimed, and use is confined to testing software for it.
Transfer-pricing comparability under TNMM requires a FAR analysis; company size may support a turnover filter, excluding high-turnover entities when determining arm's length remuneration for software development services. Where depreciation materially differs because of asset types, technology or investment levels, a cash profit level indicator excluding depreciation may compare real margins. Provision for bad and doubtful debts remains operating expenditure unless extraordinary. Free-use testing equipment supplied by an associated enterprise does not create a taxable business perquisite where ownership remains with the enterprise, no depreciation is claimed, and use is confined to testing software for it.
Note: It is a system-generated summary and is for quick reference only.