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...
GST interest on delayed GSTR-3B liabilities remains payable on the cash component until the Electronic Cash Ledger is debited, even where sufficient funds were deposited and continuously available earlier. A ledger credit evidences deposit with the Government but does not discharge an identified tax liability; debit is required for payment. The proviso excluding continuously available cash-ledger balances from interest computation operates prospectively and does not apply to earlier periods. A show-cause notice causes no defect where the taxpayer received the demand computation, responded fully, and suffered no prejudice. Failure to provide a requested personal hearing breached statutory requirements, but remand was unnecessary absent surviving substantive prejudice. Interest demands remain subject to reconciliation and credit without double recovery.
GST interest on delayed GSTR-3B liabilities remains payable on the cash component until the Electronic Cash Ledger is debited, even where sufficient funds were deposited and continuously available earlier. A ledger credit evidences deposit with the Government but does not discharge an identified tax liability; debit is required for payment. The proviso excluding continuously available cash-ledger balances from interest computation operates prospectively and does not apply to earlier periods. A show-cause notice causes no defect where the taxpayer received the demand computation, responded fully, and suffered no prejudice. Failure to provide a requested personal hearing breached statutory requirements, but remand was unnecessary absent surviving substantive prejudice. Interest demands remain subject to reconciliation and credit without double recovery.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
