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...
Customs-duty liability for pilfered imported goods arises under Section 45(3) only where the goods were unloaded in a customs area and pilfered while in the custody of a person approved under Section 45(1). Approval is a necessary precondition, so liability does not extend to pilferage before the approval became operative. A statutory port authority may be an approved custodian, and its civil responsibilities as bailee do not displace its separate revenue liability. The importer's duty exemption for pilferage operates alongside the custodian's statutory obligation. Pilferage, rather than an unexplained cargo discrepancy or non-pilferage loss, must be established through contemporaneous custody and security records.
Customs-duty liability for pilfered imported goods arises under Section 45(3) only where the goods were unloaded in a customs area and pilfered while in the custody of a person approved under Section 45(1). Approval is a necessary precondition, so liability does not extend to pilferage before the approval became operative. A statutory port authority may be an approved custodian, and its civil responsibilities as bailee do not displace its separate revenue liability. The importer's duty exemption for pilferage operates alongside the custodian's statutory obligation. Pilferage, rather than an unexplained cargo discrepancy or non-pilferage loss, must be established through contemporaneous custody and security records.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
