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...
The Appellate Tribunal's jurisdiction is excluded only for appellate orders concerning baggage, specified goods loaded for import but not unloaded, or drawback. Confiscation of Indian currency, mobile phones and a domestically registered car, coupled with a smuggling-related penalty, did not fall within those excluded categories because the items were neither imported nor exported and the car was not loaded with gold when seized. The prescribed remedy was therefore an appeal to the Appellate Tribunal, not a revision application. The writ petition was dismissed, with liberty to file the appeal within thirty days; it must be decided on merits without reference to limitation.
The Appellate Tribunal's jurisdiction is excluded only for appellate orders concerning baggage, specified goods loaded for import but not unloaded, or drawback. Confiscation of Indian currency, mobile phones and a domestically registered car, coupled with a smuggling-related penalty, did not fall within those excluded categories because the items were neither imported nor exported and the car was not loaded with gold when seized. The prescribed remedy was therefore an appeal to the Appellate Tribunal, not a revision application. The writ petition was dismissed, with liberty to file the appeal within thirty days; it must be decided on merits without reference to limitation.
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TaxTMI 
TaxTMI 
of 4902 
