Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
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.
TaxTMI 
TaxTMI 
of 4907 
