Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.
TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.
Note: It is a system-generated summary and is for quick reference only.
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