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...
Parallel Central and State GST proceedings concerning identical issues for the same assessment period require avoidance of duplicate adjudication. Where Central GST authorities issue an earlier adjudication order and an appeal against it remains pending, subsequent State GST assessment and rectification orders addressing the same issues and period cannot be sustained. The overlap between the two proceedings makes the later State GST action duplicative of the prior Central GST adjudication.
Parallel Central and State GST proceedings concerning identical issues for the same assessment period require avoidance of duplicate adjudication. Where Central GST authorities issue an earlier adjudication order and an appeal against it remains pending, subsequent State GST assessment and rectification orders addressing the same issues and period cannot be sustained. The overlap between the two proceedings makes the later State GST action duplicative of the prior Central GST adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
