TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Transfer-pricing rules apply to dealings between an Indian permanent establishment and its Head Office or overseas branches. An Additional Commissioner may act as Transfer Pricing Officer where included within the definition of Joint Commissioner and no lack of authorisation is shown. Closely linked money-market placements may be aggregated, while the Transfer Pricing Officer cannot determine the year in which income accrues. Separate remuneration for correspondent banking or incidental supervisory functions requires proof of a distinct service, resources, benefit and cost base. Profit Split Method attribution requires combined-profit analysis and allocation based on functions, assets and risks. Separately, broken-period interest on stock-in-trade securities is deductible, and unrealised profit on executory forward contracts is not taxable without real accrual.
Transfer-pricing rules apply to dealings between an Indian permanent establishment and its Head Office or overseas branches. An Additional Commissioner may act as Transfer Pricing Officer where included within the definition of Joint Commissioner and no lack of authorisation is shown. Closely linked money-market placements may be aggregated, while the Transfer Pricing Officer cannot determine the year in which income accrues. Separate remuneration for correspondent banking or incidental supervisory functions requires proof of a distinct service, resources, benefit and cost base. Profit Split Method attribution requires combined-profit analysis and allocation based on functions, assets and risks. Separately, broken-period interest on stock-in-trade securities is deductible, and unrealised profit on executory forward contracts is not taxable without real accrual.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
