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...
Section 87A, as applicable to the relevant assessment year, allows a resident individual under the concessional regime to claim a rebate from income-tax on total income, including tax computed on qualifying short-term capital gains under section 111A, where the prescribed conditions are met. Section 111A fixes the special-rate computation for those gains but does not expressly exclude the resulting tax from the rebate base. Section 115BAC(1A) preserves Chapter XII special-rate computation and does not displace the separate rebate. By contrast, section 112A(6) expressly limits rebate against tax on specified long-term capital gains. Eligibility remains dependent on assessment-year-specific statutory text, resident status, applicable income limit, and any express restriction.
Section 87A, as applicable to the relevant assessment year, allows a resident individual under the concessional regime to claim a rebate from income-tax on total income, including tax computed on qualifying short-term capital gains under section 111A, where the prescribed conditions are met. Section 111A fixes the special-rate computation for those gains but does not expressly exclude the resulting tax from the rebate base. Section 115BAC(1A) preserves Chapter XII special-rate computation and does not displace the separate rebate. By contrast, section 112A(6) expressly limits rebate against tax on specified long-term capital gains. Eligibility remains dependent on assessment-year-specific statutory text, resident status, applicable income limit, and any express restriction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
