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...
Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.
Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
