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...
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
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TaxTMI 
TaxTMI 
of 4913 
