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...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Batter-coated, deep-fried Tasty Peanuts containing gram flour, salt and spices constitute a distinct food preparation classified under the food-preparation tariff entry, attracting the stated exemption. Oil-fried Salted Peanuts with salt alone remain within the specific ground-nut entry because it expressly covers nuts roasted in oil or fat with salt, flavours or spices; their exemption is unavailable. ISD-distributed CENVAT credit is available to an authorised contract manufacturing unit producing dutiable goods for the principal, with subsequent amendments curing the earlier lacuna from inception. Penalties do not arise from bona fide tariff-classification and CENVAT-credit interpretation disputes without fraud, suppression, collusion, wilful intent to evade duty or mens rea.
Batter-coated, deep-fried Tasty Peanuts containing gram flour, salt and spices constitute a distinct food preparation classified under the food-preparation tariff entry, attracting the stated exemption. Oil-fried Salted Peanuts with salt alone remain within the specific ground-nut entry because it expressly covers nuts roasted in oil or fat with salt, flavours or spices; their exemption is unavailable. ISD-distributed CENVAT credit is available to an authorised contract manufacturing unit producing dutiable goods for the principal, with subsequent amendments curing the earlier lacuna from inception. Penalties do not arise from bona fide tariff-classification and CENVAT-credit interpretation disputes without fraud, suppression, collusion, wilful intent to evade duty or mens rea.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
