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...
GST demands alleging bogus inward supplies require proof that the supplier firm was non-existent or that tax evasion occurred. Registration of the firm and filing of relevant statutory returns supported its existence. In the absence of evidence disproving those facts or establishing tax evasion, the allegation of a bogus or non-existent firm could not sustain the GST demand or penalty. The deletion of the demand and penalty was consequently maintained, and the Revenue's appeal failed.
GST demands alleging bogus inward supplies require proof that the supplier firm was non-existent or that tax evasion occurred. Registration of the firm and filing of relevant statutory returns supported its existence. In the absence of evidence disproving those facts or establishing tax evasion, the allegation of a bogus or non-existent firm could not sustain the GST demand or penalty. The deletion of the demand and penalty was consequently maintained, and the Revenue's appeal failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
