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...
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
