Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.
Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
