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...
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
