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...
Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed.
Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed.
Note: It is a system-generated summary and is for quick reference only.
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