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...
TNMM requires operating profit and operating cost to be computed consistently for the tested party and comparable companies. A provision for doubtful debts linked to sales and trade receivables, and routine business levies such as rates and taxes, may be operating expenses because of their business nexus; income-tax on profits remains excluded. Rule 10B requires FAR-based functional comparability, reliable segmental data and reasonably accurate adjustments for material differences, including scale. A search matrix is evidentiary discipline rather than a statutory bar: an out-of-matrix comparable requires substantiated functional fit and filter compliance, while rejection solely for matrix absence is inappropriate. Contemporaneous documentation must support searches, exclusions, classifications and margin adjustments.
TNMM requires operating profit and operating cost to be computed consistently for the tested party and comparable companies. A provision for doubtful debts linked to sales and trade receivables, and routine business levies such as rates and taxes, may be operating expenses because of their business nexus; income-tax on profits remains excluded. Rule 10B requires FAR-based functional comparability, reliable segmental data and reasonably accurate adjustments for material differences, including scale. A search matrix is evidentiary discipline rather than a statutory bar: an out-of-matrix comparable requires substantiated functional fit and filter compliance, while rejection solely for matrix absence is inappropriate. Contemporaneous documentation must support searches, exclusions, classifications and margin adjustments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
