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...
Statutory demand notice sent by registered post to the drawer's correct address is deemed served under a rebuttable presumption, even if received by the drawer's mother; giving notice does not require the drawer's personal receipt. The drawer must rebut service by proving an incorrect address, non-delivery at that address, or lack of knowledge. Where the address was undisputed and used for summons and proceedings, the presumption remained unrebutted, the notice requirement was met, and the conviction was restored. A coordinate-Bench ruling treating receipt by a spouse as invalid service was per incuriam for disregarding binding larger-Bench authority and lacked binding force under Article 141.
Statutory demand notice sent by registered post to the drawer's correct address is deemed served under a rebuttable presumption, even if received by the drawer's mother; giving notice does not require the drawer's personal receipt. The drawer must rebut service by proving an incorrect address, non-delivery at that address, or lack of knowledge. Where the address was undisputed and used for summons and proceedings, the presumption remained unrebutted, the notice requirement was met, and the conviction was restored. A coordinate-Bench ruling treating receipt by a spouse as invalid service was per incuriam for disregarding binding larger-Bench authority and lacked binding force under Article 141.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
