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...
Limitation computation treats an objection filed on the next working day as timely where the statutory final day falls on a Sunday. Under section 144C, a timely objection requires the Assessing Officer to await binding Dispute Resolution Panel directions before making a final assessment. Rejection of the objection as time-barred led to the final assessment being quashed, with the objection requiring merits-based consideration after hearing the assessee. Consequential penalty proceedings remain stayed until completion of that adjudication.
Limitation computation treats an objection filed on the next working day as timely where the statutory final day falls on a Sunday. Under section 144C, a timely objection requires the Assessing Officer to await binding Dispute Resolution Panel directions before making a final assessment. Rejection of the objection as time-barred led to the final assessment being quashed, with the objection requiring merits-based consideration after hearing the assessee. Consequential penalty proceedings remain stayed until completion of that adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
