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...
Unilateral cancellation of an irrevocable joint development agreement and power of attorney was treated prima facie as ineffective where they conferred development rights on the corporate debtor and barred unilateral revocation. The construction period ran from requisite approvals and had been extended, while an alleged no-objection remained conditional and unaccepted. Land subject to mortgage and possible third-party rights was not excluded from the corporate insolvency resolution process at this stage. The landowner could intervene, and all parties were required to maintain status quo pending disposal of the appeal.
Unilateral cancellation of an irrevocable joint development agreement and power of attorney was treated prima facie as ineffective where they conferred development rights on the corporate debtor and barred unilateral revocation. The construction period ran from requisite approvals and had been extended, while an alleged no-objection remained conditional and unaccepted. Land subject to mortgage and possible third-party rights was not excluded from the corporate insolvency resolution process at this stage. The landowner could intervene, and all parties were required to maintain status quo pending disposal of the appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
