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...
Under the PMLA, a charge-sheet alleging offences under the IPC and Explosive Substances Act may establish the scheduled offence required for attachment arising from illegal granite quarrying. Properties may be attached as value equivalent to proceeds of crime where claimed lawful sources remain unsubstantiated; acquisition before the alleged criminal period does not bar equivalent-value attachment. A person who has sold the attached property lacks standing to challenge its attachment. Fair market value is determined at acquisition or possession, not by guideline or present market value, though an incorrect valuation may be immaterial where alleged proceeds are independently quantified. Recorded risk of alienation may support provisional attachment without prior communication of reasons.
Under the PMLA, a charge-sheet alleging offences under the IPC and Explosive Substances Act may establish the scheduled offence required for attachment arising from illegal granite quarrying. Properties may be attached as value equivalent to proceeds of crime where claimed lawful sources remain unsubstantiated; acquisition before the alleged criminal period does not bar equivalent-value attachment. A person who has sold the attached property lacks standing to challenge its attachment. Fair market value is determined at acquisition or possession, not by guideline or present market value, though an incorrect valuation may be immaterial where alleged proceeds are independently quantified. Recorded risk of alienation may support provisional attachment without prior communication of reasons.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
