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...
Statutory outer limits on condoning delay restrict the First Appellate Authority's jurisdiction in GST registration-cancellation appeals; equitable considerations and fact-specific constitutional orders cannot extend that power. However, where the Department has already restored registrations pursuant to the challenged appellate orders, its challenge may become infructuous because reversing those orders without addressing the consequences of implementation offers no effective relief. Failure or inability to seek revocation through Rule 23, including where the common portal blocks a late application, does not extinguish the independent statutory right to appeal cancellation of GST registration.
Statutory outer limits on condoning delay restrict the First Appellate Authority's jurisdiction in GST registration-cancellation appeals; equitable considerations and fact-specific constitutional orders cannot extend that power. However, where the Department has already restored registrations pursuant to the challenged appellate orders, its challenge may become infructuous because reversing those orders without addressing the consequences of implementation offers no effective relief. Failure or inability to seek revocation through Rule 23, including where the common portal blocks a late application, does not extinguish the independent statutory right to appeal cancellation of GST registration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
