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...
PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim.
PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
