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...
Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.
Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
