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...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
