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...
Written authorisation and a confidentiality undertaking are required before a suspended director's non-voting representative participates in Committee of Creditors deliberations on commercially sensitive resolution plans. Earlier participation does not waive these safeguards, and no adjournment for later regularisation is mandatory. Resolution-plan materials may be disclosed after the undertaking is received, provided disclosure occurs before voting closes and permits meaningful representations. Committee proceedings and an approved, implemented plan are not to be disturbed for procedural objections absent demonstrated substantive prejudice.
Written authorisation and a confidentiality undertaking are required before a suspended director's non-voting representative participates in Committee of Creditors deliberations on commercially sensitive resolution plans. Earlier participation does not waive these safeguards, and no adjournment for later regularisation is mandatory. Resolution-plan materials may be disclosed after the undertaking is received, provided disclosure occurs before voting closes and permits meaningful representations. Committee proceedings and an approved, implemented plan are not to be disturbed for procedural objections absent demonstrated substantive prejudice.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
