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...
BAS - services rendered by the foreign based vendors - onsite services performed outside India - reverse charge - It is clear that the destination has to be decided on the basis of the place of consumption, not the place of performance of service - As such, the appellants are liable to pay service tax on the services, which they received from various vendors located outside India. - AT
BAS - services rendered by the foreign based vendors - onsite services performed outside India - reverse charge - It is clear that the destination has to be decided on the basis of the place of consumption, not the place of performance of service - As such, the appellants are liable to pay service tax on the services, which they received from various vendors located outside India. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4925 
