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...
GST assessment order was challenged on the basis that zero-rated supplies entitled the petitioner to a refund under the IGST and CGST/TNGST provisions. The assessment also required payment of interest and penalty under the respective GST enactments. No procedural irregularity was found in the assessment process, and the writ challenge was dismissed. The dispute therefore centred on the procedural validity of the assessment despite the asserted entitlement to a refund for zero-rated supplies.
GST assessment order was challenged on the basis that zero-rated supplies entitled the petitioner to a refund under the IGST and CGST/TNGST provisions. The assessment also required payment of interest and penalty under the respective GST enactments. No procedural irregularity was found in the assessment process, and the writ challenge was dismissed. The dispute therefore centred on the procedural validity of the assessment despite the asserted entitlement to a refund for zero-rated supplies.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
