Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
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...
Page of 4918
Press 'Enter' after typing page number.
341 to 360 of 98359 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Fraud-classification action cannot rest solely on a forensic...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclusive evidence.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Fraud-classification action cannot rest solely on a forensic audit report that is inconclusive, based on limited lender-provided material, and qualified because complete records were unavailable. Where the borrower is in CIRP and liquidation, the erstwhile management lacks control and relevant books and records may be seized, reinforcing the report's evidentiary limitations. A show cause notice founded on the same report previously treated as inconclusive in relation to the lead bank remains defective despite the borrower filing a reply. The fraud-classification notice, resulting order, and consequential action were set aside, while fresh action on conclusive evidentiary material remains open.
Fraud-classification action cannot rest solely on a forensic audit report that is inconclusive, based on limited lender-provided material, and qualified because complete records were unavailable. Where the borrower is in CIRP and liquidation, the erstwhile management lacks control and relevant books and records may be seized, reinforcing the report's evidentiary limitations. A show cause notice founded on the same report previously treated as inconclusive in relation to the lead bank remains defective despite the borrower filing a reply. The fraud-classification notice, resulting order, and consequential action were set aside, while fresh action on conclusive evidentiary material remains open.
Note: It is a system-generated summary and is for quick reference only.