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...
Oppression and mismanagement allegations concerning group-asset and intellectual-property transfers, debt conversion, discounted share allotment and minority dilution require specific findings on the entire material and their cumulative effect; commercial justification cannot replace that inquiry. The dismissal was set aside and the company petition remanded, with status quo over shareholding, assets and liabilities restored pending adjudication. A clean-hands finding denying equitable relief must rest on clear, cogent record-based findings where meeting-related material permits competing interpretations. Perjury directions require precise allegations, meaningful opportunity to respond, identified false statements, reasons, and findings on oath, intentional falsity and requirements for further action; unsupported directions against shareholders and a creditor were set aside.
Oppression and mismanagement allegations concerning group-asset and intellectual-property transfers, debt conversion, discounted share allotment and minority dilution require specific findings on the entire material and their cumulative effect; commercial justification cannot replace that inquiry. The dismissal was set aside and the company petition remanded, with status quo over shareholding, assets and liabilities restored pending adjudication. A clean-hands finding denying equitable relief must rest on clear, cogent record-based findings where meeting-related material permits competing interpretations. Perjury directions require precise allegations, meaningful opportunity to respond, identified false statements, reasons, and findings on oath, intentional falsity and requirements for further action; unsupported directions against shareholders and a creditor were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
