Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Arm's length price determination under TNMM permits exclusion of comparables initially selected by either party where Rule 10B comparability requirements are not met; initial selection creates no estoppel. Related-party transaction filters may exclude companies whose profitability is materially influenced by controlled dealings, including transactions affecting operating costs rather than only revenue. Contact-centre service benchmarking also requires exclusion where financial results are abnormal, outsourcing models materially differ, segmental profitability is unreliable, or diversified, branded, or higher-end service operations lack reliable segmental data. Material profitability differences must be reliably adjusted; otherwise, the company cannot remain an uncontrolled comparable.
Arm's length price determination under TNMM permits exclusion of comparables initially selected by either party where Rule 10B comparability requirements are not met; initial selection creates no estoppel. Related-party transaction filters may exclude companies whose profitability is materially influenced by controlled dealings, including transactions affecting operating costs rather than only revenue. Contact-centre service benchmarking also requires exclusion where financial results are abnormal, outsourcing models materially differ, segmental profitability is unreliable, or diversified, branded, or higher-end service operations lack reliable segmental data. Material profitability differences must be reliably adjusted; otherwise, the company cannot remain an uncontrolled comparable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
