https://www.taxtmi.com/caselaws?id=389487 Closely linked intra-group service charges may be benchmarked with the overall software-services transactions under TNMM where the taxpayer's operating margin exceeds comparables; a separate nil-value benefit or necessity test is unwarranted. Foreign-currency loans require benchmarking against LIBOR-based lending rates, while delayed trade receivables from business sales cannot automatically be recharacterised as unsecured loans where overall TNMM results are arm's length. Goodwill arising on amalgamation qualifies for depreciation. ESOP reimbursement is deductible employee compensation when it crystallises, with withholding arising upon employee exercise and receipt of the perquisite. Transfer-related land expenditure is deductible in computing capital gains, and actual share-sale consideration cannot be replaced by notional value without statutory authority. TDS and MAT credits require factual verification; interest is consequential or verification-dependent. en-us Fri, 29 Nov 2019 00:00:00 +0530 Mon, 09 Dec 2019 14:51:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389487 Closely linked intra-group service charges may be benchmarked with the overall software-services transactions under TNMM where the taxpayer's operating margin exceeds comparables; a separate nil-value benefit or necessity test is unwarranted. Foreign-currency loans require benchmarking against LIBOR-based lending rates, while delayed trade receivables from business sales cannot automatically be recharacterised as unsecured loans where overall TNMM results are arm's length. Goodwill arising on amalgamation qualifies for depreciation. ESOP reimbursement is deductible employee compensation when it crystallises, with withholding arising upon employee exercise and receipt of the perquisite. Transfer-related land expenditure is deductible in computing capital gains, and actual share-sale consideration cannot be replaced by notional value without statutory authority. TDS and MAT credits require factual verification; interest is consequential or verification-dependent. Case-Laws Income Tax Fri, 29 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389487