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...
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
