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...
Unchallenged order-in-original conditions requiring payment of customs duty, redemption fine and penalty for release of detained gold jewellery cannot be assailed indirectly after the available remedies against that order were not pursued. Earlier writ proceedings directing release in accordance with the order do not determine its validity. Recovery of customs duty as a condition of redemption therefore remains enforceable. Detention charges recovered on release may be challenged only upon establishing that their recovery contravened statutory provisions; no such statutory infirmity was shown.
Unchallenged order-in-original conditions requiring payment of customs duty, redemption fine and penalty for release of detained gold jewellery cannot be assailed indirectly after the available remedies against that order were not pursued. Earlier writ proceedings directing release in accordance with the order do not determine its validity. Recovery of customs duty as a condition of redemption therefore remains enforceable. Detention charges recovered on release may be challenged only upon establishing that their recovery contravened statutory provisions; no such statutory infirmity was shown.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
