Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Voluntary payments by a partnership firm towards an outstanding tax demand of one partner were not treated as forced recovery merely because the firm's bank account had been attached. The firm did not establish that the Department had been notified of its change from proprietorship to partnership before payment. Claims arising from payment of a partner's liability constituted inter se disputes among partners and did not demonstrate illegality, error, or arbitrariness in the Department's action. The refund claim was denied and the writ petition dismissed.
Voluntary payments by a partnership firm towards an outstanding tax demand of one partner were not treated as forced recovery merely because the firm's bank account had been attached. The firm did not establish that the Department had been notified of its change from proprietorship to partnership before payment. Claims arising from payment of a partner's liability constituted inter se disputes among partners and did not demonstrate illegality, error, or arbitrariness in the Department's action. The refund claim was denied and the writ petition dismissed.
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