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...
Classification of imported stainless-steel melting scrap requires consignment-specific, reliable evidence; test reports for later consignments cannot displace a separately finalised assessment. Pre-shipment inspection and Chartered Engineer reports identifying goods as scrap remain material where chemical or laboratory evidence is inadequate, and buyer statements not tested under the prescribed evidentiary procedure cannot establish prime material. Uniform dimensions or orderly stacking do not alone establish prime material, while revaluation requires support for additional consideration. Goods cleared without bond or undertaking and unavailable for confiscation cannot be absolutely confiscated. Director penalties require a specific basis for personal responsibility. All consignments were treated as scrap, with enhanced values, confiscation and penalties set aside; demurrage waiver was directed for detained goods.
Classification of imported stainless-steel melting scrap requires consignment-specific, reliable evidence; test reports for later consignments cannot displace a separately finalised assessment. Pre-shipment inspection and Chartered Engineer reports identifying goods as scrap remain material where chemical or laboratory evidence is inadequate, and buyer statements not tested under the prescribed evidentiary procedure cannot establish prime material. Uniform dimensions or orderly stacking do not alone establish prime material, while revaluation requires support for additional consideration. Goods cleared without bond or undertaking and unavailable for confiscation cannot be absolutely confiscated. Director penalties require a specific basis for personal responsibility. All consignments were treated as scrap, with enhanced values, confiscation and penalties set aside; demurrage waiver was directed for detained goods.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
