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...
Deletion of reassessment additions through an appeal-effect order removed the basis for concealment penalty, as no concealed income remained when the penalty order was passed. The Tribunal therefore deleted the concealment penalty. Penalty for non-compliance with statutory notices was also deleted where the assessee had stated, through affidavits, unfamiliarity with tax law and reliance on a professional for compliance. The Tribunal treated these circumstances as warranting relief in the interest of justice, allowing both appeals and deleting both penalties.
Deletion of reassessment additions through an appeal-effect order removed the basis for concealment penalty, as no concealed income remained when the penalty order was passed. The Tribunal therefore deleted the concealment penalty. Penalty for non-compliance with statutory notices was also deleted where the assessee had stated, through affidavits, unfamiliarity with tax law and reliance on a professional for compliance. The Tribunal treated these circumstances as warranting relief in the interest of justice, allowing both appeals and deleting both penalties.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
