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...
Reasoned and speaking appellate GST orders must address material grounds of appeal and cited precedents; merely confirming an ex parte demand for lack of satisfactory evidence fails to exercise appellate jurisdiction. Where original adjudication occurred ex parte and objections concerning notice, relied-upon documents, and hearing remain unresolved, remand for fresh original adjudication preserves the appellate remedy. Fresh proceedings require identification and access to relied-upon documents, a reasonable opportunity to respond, an effective personal hearing, and reasoned findings based on evidence. Non-participation without sufficient cause permits determination on the existing record, but not without reasons.
Reasoned and speaking appellate GST orders must address material grounds of appeal and cited precedents; merely confirming an ex parte demand for lack of satisfactory evidence fails to exercise appellate jurisdiction. Where original adjudication occurred ex parte and objections concerning notice, relied-upon documents, and hearing remain unresolved, remand for fresh original adjudication preserves the appellate remedy. Fresh proceedings require identification and access to relied-upon documents, a reasonable opportunity to respond, an effective personal hearing, and reasoned findings based on evidence. Non-participation without sufficient cause permits determination on the existing record, but not without reasons.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
