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...
Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.
Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
