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...
Condonation of delay in filing appeal is governed by Section 5 of Limitation Act. When special statute provides period for initiating proceeding and authority to condone delay without specifying time limit, Section 5 applies. Central Board of Indirect Taxes and Customs extended time for filing appeal against certain orders under BGST Act beyond statutory period. Extraordinary jurisdiction under Article 226 cannot be invoked when alternate remedies available and assessee failed to avail them diligently within stipulated time.
Condonation of delay in filing appeal is governed by Section 5 of Limitation Act. When special statute provides period for initiating proceeding and authority to condone delay without specifying time limit, Section 5 applies. Central Board of Indirect Taxes and Customs extended time for filing appeal against certain orders under BGST Act beyond statutory period. Extraordinary jurisdiction under Article 226 cannot be invoked when alternate remedies available and assessee failed to avail them diligently within stipulated time.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
