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...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Reasoned and speaking appellate orders require consideration of the appellants' material grounds and cited authorities; a bare affirmation of original orders in identical terms fails to exercise appellate jurisdiction. Where original adjudication proceeded ex parte and objections concerning notice, relied-upon documents, and personal hearing remain unexamined, remand preserves the effective appellate remedy rather than a merits decision at the appellate stage. The appellate and original orders were set aside, with fresh adjudication requiring identification and availability of relied-upon documents, reasonable time to reply, an effective personal hearing, and reasoned orders.
Reasoned and speaking appellate orders require consideration of the appellants' material grounds and cited authorities; a bare affirmation of original orders in identical terms fails to exercise appellate jurisdiction. Where original adjudication proceeded ex parte and objections concerning notice, relied-upon documents, and personal hearing remain unexamined, remand preserves the effective appellate remedy rather than a merits decision at the appellate stage. The appellate and original orders were set aside, with fresh adjudication requiring identification and availability of relied-upon documents, reasonable time to reply, an effective personal hearing, and reasoned orders.
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TaxTMI 
TaxTMI 
of 4915 
