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...
Input Tax Credit reconciliation through GSTR-2A/2B, GSTR-3B and the annual return may provide prima facie evidence of available credit. A tax demand alleging excess utilisation of Input Tax Credit requires reconsideration where those material records were not duly examined, with an opportunity to establish the credit claimed. Verification of asserted recovery of part of the demand is also required before releasing a bank attachment. The tax demand was set aside for fresh consideration, and the attachment was to be lifted subject to verification of recovery.
Input Tax Credit reconciliation through GSTR-2A/2B, GSTR-3B and the annual return may provide prima facie evidence of available credit. A tax demand alleging excess utilisation of Input Tax Credit requires reconsideration where those material records were not duly examined, with an opportunity to establish the credit claimed. Verification of asserted recovery of part of the demand is also required before releasing a bank attachment. The tax demand was set aside for fresh consideration, and the attachment was to be lifted subject to verification of recovery.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
