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...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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First appellate authorities with powers coterminous with the Assessing Officer may examine fresh evidence filed in appeal and may obtain a remand report where verification is required. Rejecting fresh purchase, vendor-balance, sales, expense, and tax-deduction details solely because complete material was not furnished during assessment leaves factual disputes unverified. Additions and disallowances founded on such discrepancies require fresh verification through de novo adjudication, with an adequate hearing opportunity and taxpayer cooperation.
First appellate authorities with powers coterminous with the Assessing Officer may examine fresh evidence filed in appeal and may obtain a remand report where verification is required. Rejecting fresh purchase, vendor-balance, sales, expense, and tax-deduction details solely because complete material was not furnished during assessment leaves factual disputes unverified. Additions and disallowances founded on such discrepancies require fresh verification through de novo adjudication, with an adequate hearing opportunity and taxpayer cooperation.
Note: It is a system-generated summary and is for quick reference only.