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...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Credit-rating restrictions for promoter-connected entities extend conditions concerning common chairmen, directors or employees to securities issued by a promoter's borrowers and subsidiaries, not only associates. Regulation 27(1) was ambiguous on the scope of those conditions and required harmonious construction with the related conflict-of-interest regime in Regulation 28V. Contemporaneous regulatory material and legislative-committee material supported that interpretation. The penalty order was consequently set aside and the appeal allowed.
Credit-rating restrictions for promoter-connected entities extend conditions concerning common chairmen, directors or employees to securities issued by a promoter's borrowers and subsidiaries, not only associates. Regulation 27(1) was ambiguous on the scope of those conditions and required harmonious construction with the related conflict-of-interest regime in Regulation 28V. Contemporaneous regulatory material and legislative-committee material supported that interpretation. The penalty order was consequently set aside and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4901 
