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...
Rectification of a mistake apparent from the record is confined to patent, self-evident errors and cannot reopen the merits or adopt another possible view. Challenges to the effect of show cause notices, adjudication findings, penal provisions and statutory consequences required reconsideration of the concluded penalty finding for facilitative conduct. As no accidental omission or apparent error was shown, the rectification applications were rejected and the penalty order remained unchanged.
Rectification of a mistake apparent from the record is confined to patent, self-evident errors and cannot reopen the merits or adopt another possible view. Challenges to the effect of show cause notices, adjudication findings, penal provisions and statutory consequences required reconsideration of the concluded penalty finding for facilitative conduct. As no accidental omission or apparent error was shown, the rectification applications were rejected and the penalty order remained unchanged.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
