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...
Corporate veil lifting for real estate project resolution treated the developer and the land-owning special purpose company as a single economic entity, bringing the leasehold land within the restored resolution plan. Allottee claims arising from the same project were addressed through completion and delivery under that plan, leaving no independently due debt to support a separate insolvency process. A parallel CIRP over the project land would impose a moratorium and vest management in an insolvency professional, obstructing implementation of the restored plan. The Monitoring Committee responsible for plan implementation had standing as an aggrieved person, and binding Supreme Court precedent required consideration. Allottees' remedy lay in enforcing the restored plan.
Corporate veil lifting for real estate project resolution treated the developer and the land-owning special purpose company as a single economic entity, bringing the leasehold land within the restored resolution plan. Allottee claims arising from the same project were addressed through completion and delivery under that plan, leaving no independently due debt to support a separate insolvency process. A parallel CIRP over the project land would impose a moratorium and vest management in an insolvency professional, obstructing implementation of the restored plan. The Monitoring Committee responsible for plan implementation had standing as an aggrieved person, and binding Supreme Court precedent required consideration. Allottees' remedy lay in enforcing the restored plan.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
