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...
Skill-based online-game prizes fall within taxable income; the term "winnings" is not limited to chance-based games. However, online-gaming taxability applies only to real net winnings, not gross wallet credits. Repeated circulation of funds, player buy-ins and recycled gaming amounts cannot independently constitute taxable winnings, notwithstanding the bar on deducting expenditure. Where gaming activity results in a net loss and no real net winnings arise, an addition computed on gross online-gaming credits is unsustainable and must be deleted.
Skill-based online-game prizes fall within taxable income; the term "winnings" is not limited to chance-based games. However, online-gaming taxability applies only to real net winnings, not gross wallet credits. Repeated circulation of funds, player buy-ins and recycled gaming amounts cannot independently constitute taxable winnings, notwithstanding the bar on deducting expenditure. Where gaming activity results in a net loss and no real net winnings arise, an addition computed on gross online-gaming credits is unsustainable and must be deleted.
Note: It is a system-generated summary and is for quick reference only.