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...
Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.
Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
