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...
For non-notified goods such as black pepper and socks, the Customs Act places the burden on Revenue to prove their smuggled character before confiscation can be sustained. Failure to discharge that burden means the goods are not liable to confiscation, and penalties imposed solely as a consequence of confiscation cannot stand. The confiscation order and consequential penalties were set aside, with consequential relief.
For non-notified goods such as black pepper and socks, the Customs Act places the burden on Revenue to prove their smuggled character before confiscation can be sustained. Failure to discharge that burden means the goods are not liable to confiscation, and penalties imposed solely as a consequence of confiscation cannot stand. The confiscation order and consequential penalties were set aside, with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
