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...
Review of an original regular-bail grant is limited to perversity, illegality, non-application of mind, irrelevant considerations, or omission of relevant circumstances; it differs from cancellation based on later misconduct, breach of conditions, or supervening circumstances. A connected PMLA bail order arising from the same FIR may be relevant but is not conclusive in CBI proceedings, which require an independent assessment of each accused's role. In the alleged unauthorised telephone-interception proceedings, consideration of objections, individual roles, and bail conditions precluded a finding of mechanical parity or defective discretion. The challenges to regular bail were dismissed, and the Trial Court must remain uninfluenced by prima facie bail observations.
Review of an original regular-bail grant is limited to perversity, illegality, non-application of mind, irrelevant considerations, or omission of relevant circumstances; it differs from cancellation based on later misconduct, breach of conditions, or supervening circumstances. A connected PMLA bail order arising from the same FIR may be relevant but is not conclusive in CBI proceedings, which require an independent assessment of each accused's role. In the alleged unauthorised telephone-interception proceedings, consideration of objections, individual roles, and bail conditions precluded a finding of mechanical parity or defective discretion. The challenges to regular bail were dismissed, and the Trial Court must remain uninfluenced by prima facie bail observations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
