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...
Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.
Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
