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...
Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
