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...
Whether assessee is not assessable to Wealth Tax - When the wholly owned subsidiary could be considered as a company in which public are substantially interested, the assessee-company ought to be treated as a company in which public are substantially interested. - HC
Whether assessee is not assessable to Wealth Tax - When the wholly owned subsidiary could be considered as a company in which public are substantially interested, the assessee-company ought to be treated as a company in which public are substantially interested. - HC
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