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...
Pre-movement e-way bill compliance requires the e-way bill to be generated before goods begin moving, with the tax invoice and e-way bill carried by the person in charge. Generating those documents only after interception does not cure transportation undertaken without them. Their absence at interception creates a rebuttable presumption of intent to evade tax, which may be displaced only by a reasonable explanation. The explanation did not rebut that presumption, and the detention-related penalty under section 129 was sustained.
Pre-movement e-way bill compliance requires the e-way bill to be generated before goods begin moving, with the tax invoice and e-way bill carried by the person in charge. Generating those documents only after interception does not cure transportation undertaken without them. Their absence at interception creates a rebuttable presumption of intent to evade tax, which may be displaced only by a reasonable explanation. The explanation did not rebut that presumption, and the detention-related penalty under section 129 was sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
