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...
Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
