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...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.
Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4908 
