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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...
Documents relied upon in a respondent's complaint and relevant to whether property attachment should continue during the complaint's pendency must be taken on record in the related appeals. The refusal to admit those documents was set aside, and documents already filed were treated as part of the record. Costs imposed for delayed applications to file documents remained payable because the appellants had the documents in their knowledge and possession but sought to place them on record only when the appeals were listed for final hearing.
Documents relied upon in a respondent's complaint and relevant to whether property attachment should continue during the complaint's pendency must be taken on record in the related appeals. The refusal to admit those documents was set aside, and documents already filed were treated as part of the record. Costs imposed for delayed applications to file documents remained payable because the appellants had the documents in their knowledge and possession but sought to place them on record only when the appeals were listed for final hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
