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...
Unaccounted quarry sales establish suppressed business transactions, but only the profit reasonably embedded in those sales is taxable; extraction, production and operating costs cannot be treated as income absent evidence of unexplained funding. Profit estimation must have a rational link to the taxpayer's own historical results and accounted-business profitability; an unverified external gross-profit margin cannot be substituted for net profit. The voluntarily offered profit rates were accepted, displacing the higher rate. Cash sales captured in seized data cannot be added separately where aggregate records, annual accounts and GST disclosures show they were already included in disclosed turnover; a further profit addition would duplicate the same sales.
Unaccounted quarry sales establish suppressed business transactions, but only the profit reasonably embedded in those sales is taxable; extraction, production and operating costs cannot be treated as income absent evidence of unexplained funding. Profit estimation must have a rational link to the taxpayer's own historical results and accounted-business profitability; an unverified external gross-profit margin cannot be substituted for net profit. The voluntarily offered profit rates were accepted, displacing the higher rate. Cash sales captured in seized data cannot be added separately where aggregate records, annual accounts and GST disclosures show they were already included in disclosed turnover; a further profit addition would duplicate the same sales.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
