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...
One-time settlement by a personal guarantor with the sole financial creditor does not remove a corporate debtor from liquidation or alter the process except through statutory routes. An asset transfer approved after failed auctions may remain undisturbed where the consideration exceeds the reserve price and highest bid, despite procedural non-compliance, because it advances value maximisation. A forfeited earnest money deposit remains part of the liquidation estate and must be restored once the creditor's claim is fully settled. Settlement does not confer financial creditor status on a personal guarantor without assignment or substitution of debt; the admitted operational creditor receives distribution under the statutory waterfall before any residual promoter entitlement. Liquidator remuneration and expenses remain payable from the estate.
One-time settlement by a personal guarantor with the sole financial creditor does not remove a corporate debtor from liquidation or alter the process except through statutory routes. An asset transfer approved after failed auctions may remain undisturbed where the consideration exceeds the reserve price and highest bid, despite procedural non-compliance, because it advances value maximisation. A forfeited earnest money deposit remains part of the liquidation estate and must be restored once the creditor's claim is fully settled. Settlement does not confer financial creditor status on a personal guarantor without assignment or substitution of debt; the admitted operational creditor receives distribution under the statutory waterfall before any residual promoter entitlement. Liquidator remuneration and expenses remain payable from the estate.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
