Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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...
Manufacturing scrap generated in the ordinary manufacturing process and directly connected with goods produced by eligible undertakings qualifies for profit-linked deduction. Additional exempt-income expenditure cannot be disallowed through a mechanical formula without recorded dissatisfaction, having regard to the accounts, with the voluntary disallowance; no further disallowance was warranted where it exceeded exempt dividend income. Corporate guarantees to associated enterprises are international transactions, with guarantee commission restricted to 0.35% under consistent prior-year treatment; consistency also precluded notional interest on unchanged equity contributions. Common-expense allocation under an established incremental approach was accepted. Royalty benchmarking was remitted for a fresh arm's-length review after disclosure of the search strategy and hearing, while a challenge without an underlying adjustment was redundant.
Manufacturing scrap generated in the ordinary manufacturing process and directly connected with goods produced by eligible undertakings qualifies for profit-linked deduction. Additional exempt-income expenditure cannot be disallowed through a mechanical formula without recorded dissatisfaction, having regard to the accounts, with the voluntary disallowance; no further disallowance was warranted where it exceeded exempt dividend income. Corporate guarantees to associated enterprises are international transactions, with guarantee commission restricted to 0.35% under consistent prior-year treatment; consistency also precluded notional interest on unchanged equity contributions. Common-expense allocation under an established incremental approach was accepted. Royalty benchmarking was remitted for a fresh arm's-length review after disclosure of the search strategy and hearing, while a challenge without an underlying adjustment was redundant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
