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...
GST law bars overlapping Central and State departmental proceedings when they assess or recover the same tax liability arising from the same contravention. The prohibition does not extend to distinct infractions solely because they produce similar liabilities or deficiencies. A consolidated GST demand that included FY 2017-18 and FY 2018-19, already covered by State proceedings, had to exclude those overlapping periods. The consolidated demand was quashed, and fresh determination was confined to periods not subject to the State proceedings.
GST law bars overlapping Central and State departmental proceedings when they assess or recover the same tax liability arising from the same contravention. The prohibition does not extend to distinct infractions solely because they produce similar liabilities or deficiencies. A consolidated GST demand that included FY 2017-18 and FY 2018-19, already covered by State proceedings, had to exclude those overlapping periods. The consolidated demand was quashed, and fresh determination was confined to periods not subject to the State proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
