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...
Clandestine manufacture and clearance allegations require sufficient tangible evidence establishing a reliable chain from unaccounted inputs and production to transport, buyers and receipt of sale proceeds. Loose handwritten sheets, WhatsApp printouts, Tally data and transporter records maintained or recovered from third parties cannot substantiate a demand unless their authorship, provenance, custody, preservation, integrity and nexus with the manufacturer are proved. Unretracted statements showing a marketing or distribution connection do not remedy defects in electronic evidence. Inferences drawn through assumed material consumption, manufacture and removal are impermissible successive presumptions. Unverified records may justify further investigation but cannot, without independent corroboration, sustain duty, interest or penalties.
Clandestine manufacture and clearance allegations require sufficient tangible evidence establishing a reliable chain from unaccounted inputs and production to transport, buyers and receipt of sale proceeds. Loose handwritten sheets, WhatsApp printouts, Tally data and transporter records maintained or recovered from third parties cannot substantiate a demand unless their authorship, provenance, custody, preservation, integrity and nexus with the manufacturer are proved. Unretracted statements showing a marketing or distribution connection do not remedy defects in electronic evidence. Inferences drawn through assumed material consumption, manufacture and removal are impermissible successive presumptions. Unverified records may justify further investigation but cannot, without independent corroboration, sustain duty, interest or penalties.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
