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...
PMLA attachment may extend to Indian property of equivalent value where alleged proceeds of crime remain abroad, including property acquired before the alleged criminal activity or held in a spouse's name if funded by the accused and unsupported by an independent untainted source. Money-laundering is treated as a continuing offence, with timing assessed by reference to laundering acts and attachment; the value-of-proceeds limb independently supports equivalent-value attachment. A provisional attachment order may meet the reasons-to-believe requirement by recording the material, belief and risk of frustrating confiscation, without separate communication. Attachment proceedings do not determine the merits of a pending scheduled offence. Physical possession during pending prosecution is restricted to exceptional circumstances.
PMLA attachment may extend to Indian property of equivalent value where alleged proceeds of crime remain abroad, including property acquired before the alleged criminal activity or held in a spouse's name if funded by the accused and unsupported by an independent untainted source. Money-laundering is treated as a continuing offence, with timing assessed by reference to laundering acts and attachment; the value-of-proceeds limb independently supports equivalent-value attachment. A provisional attachment order may meet the reasons-to-believe requirement by recording the material, belief and risk of frustrating confiscation, without separate communication. Attachment proceedings do not determine the merits of a pending scheduled offence. Physical possession during pending prosecution is restricted to exceptional circumstances.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
