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...
Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises.
Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
