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...
Reassessment founded on a share transaction wrongly mapped to an assessee's PAN is unsustainable where the underlying information concerns another person. Initiating proceedings without verification merely to avoid limitation constitutes a colourable exercise of reassessment power. The reassessment order and consequential notice were quashed, and costs were awarded in the proceedings.
Reassessment founded on a share transaction wrongly mapped to an assessee's PAN is unsustainable where the underlying information concerns another person. Initiating proceedings without verification merely to avoid limitation constitutes a colourable exercise of reassessment power. The reassessment order and consequential notice were quashed, and costs were awarded in the proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
