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...
Customs exemption amendments cannot be applied to imported second-hand specialised equipment handed to the first carrier before the amendment took effect, where multimodal transport is recognised under the Customs Act. A request for provisional release must therefore be considered under Section 110A and cannot be refused merely by relying on the subsequent amendment. Earlier directions concerning provisional release of similar goods remain applicable where no distinguishing feature exists. Upon compliance with lawful conditions, the goods are to be provisionally released pending adjudication.
Customs exemption amendments cannot be applied to imported second-hand specialised equipment handed to the first carrier before the amendment took effect, where multimodal transport is recognised under the Customs Act. A request for provisional release must therefore be considered under Section 110A and cannot be refused merely by relying on the subsequent amendment. Earlier directions concerning provisional release of similar goods remain applicable where no distinguishing feature exists. Upon compliance with lawful conditions, the goods are to be provisionally released pending adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
