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 32A(1) of the Insolvency and Bankruptcy Code ends a corporate debtor's liability for offences committed before commencement of CIRP once an approved resolution plan results in a qualifying change in management or control. The immunity can protect a successor company that takes over and amalgamates with the former corporate debtor, preventing civil or criminal liability for the predecessor's pre-CIRP acts, including alleged Air Act offences. Its application is company-specific: proceedings may be quashed against the protected successor without affecting prosecution of the remaining accused.
Section 32A(1) of the Insolvency and Bankruptcy Code ends a corporate debtor's liability for offences committed before commencement of CIRP once an approved resolution plan results in a qualifying change in management or control. The immunity can protect a successor company that takes over and amalgamates with the former corporate debtor, preventing civil or criminal liability for the predecessor's pre-CIRP acts, including alleged Air Act offences. Its application is company-specific: proceedings may be quashed against the protected successor without affecting prosecution of the remaining accused.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
