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...
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...
Closely linked technical know-how fee and poultry feed premix purchase transactions may be aggregated for transfer-pricing purposes under Rules 10AD(d) and 10B. Where know-how fees are netted against premix purchase costs and the associated enterprise's invoice prices are accepted under the CUP method, the resulting reduction in net purchase cost supports arm's length treatment; the separate adjustment for know-how fees was deleted. Related-party performance incentives to directors cannot be disallowed merely because of the relationship. Disallowance requires material showing that expenditure is excessive or unreasonable against fair market value, legitimate business needs, or benefits derived. In the absence of findings or comparables, the incentive provision disallowance was deleted.
Closely linked technical know-how fee and poultry feed premix purchase transactions may be aggregated for transfer-pricing purposes under Rules 10AD(d) and 10B. Where know-how fees are netted against premix purchase costs and the associated enterprise's invoice prices are accepted under the CUP method, the resulting reduction in net purchase cost supports arm's length treatment; the separate adjustment for know-how fees was deleted. Related-party performance incentives to directors cannot be disallowed merely because of the relationship. Disallowance requires material showing that expenditure is excessive or unreasonable against fair market value, legitimate business needs, or benefits derived. In the absence of findings or comparables, the incentive provision disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
