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...
Jurisdiction - power under IGST to issue such notice - So far as respondent No.1 is concerned, they are not pursuing anything against the petitioner. As per reply filed on behalf of respondents No.1 to 3, the Excise and Taxation Officer has already passed the order dated 22.07.2019 (Annexure P-14), and the same is appealable. - Petition dismissed - HC
Jurisdiction - power under IGST to issue such notice - So far as respondent No.1 is concerned, they are not pursuing anything against the petitioner. As per reply filed on behalf of respondents No.1 to 3, the Excise and Taxation Officer has already passed the order dated 22.07.2019 (Annexure P-14), and the same is appealable. - Petition dismissed - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
