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...
Compulsory-acquisition compensation under the National Highways Act that remained unpaid on 31 December 2014 and was received in FY 2015-16 qualified for exemption under section 96 of the RFCTLARR Act. The exemption applied notwithstanding the absence of a specific corresponding exemption in the Income-tax Act, resulting in deletion of the long-term capital-gains addition. Interest received for delayed payment of that compensation was separately taxable as income from other sources under binding jurisdictional High Court precedent. The capital-gains addition was deleted, while the addition for delayed-payment interest was sustained.
Compulsory-acquisition compensation under the National Highways Act that remained unpaid on 31 December 2014 and was received in FY 2015-16 qualified for exemption under section 96 of the RFCTLARR Act. The exemption applied notwithstanding the absence of a specific corresponding exemption in the Income-tax Act, resulting in deletion of the long-term capital-gains addition. Interest received for delayed payment of that compensation was separately taxable as income from other sources under binding jurisdictional High Court precedent. The capital-gains addition was deleted, while the addition for delayed-payment interest was sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
