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...
Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.
Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
