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...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.
Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
