This is a significant judgment which emphasises the comparability standards required for the application of the CUP method and signifies the relevance of ‘business considerations’ while determining the arm’s length price. Whereas the original judgement indicated the Tax Court’s unwillingness to look at the overall business relationship within the group, the FCA has taken a much broader view, recognising what a reasonable business person dealing at arm’s length would consider (such as the use of intangibles). The FCA’s reference to “business reality” is a breath of fresh air for taxpayers.
Reopening of tax assessment beyond four years on the basis of a retrospective amendment is not justified, if the assessee has fully and truly disclosed all the material facts necessary during the original assessment proceedings
The Supreme Court (SC) has clarified the nominee of a depositor in a bank does not get ownership of the money in the account after death of the depositor. The nominee gets exclusive right to receive the money lying in the account. It gives him all th
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