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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Section 35(6) requires unaccounted tobacco stock found during a business-premises survey to be treated as supplied and subjected to tax determination under the prescribed statutory procedure. Direct confiscation proceedings cannot be used to impose tax, penalty and fine solely because excess or unaccounted stock is found; proceedings must instead be initiated under section 73 or 74. On that basis, the first appellate orders setting aside confiscation-based tax, penalty and fine were upheld, and the revenue appeals were dismissed.
Section 35(6) requires unaccounted tobacco stock found during a business-premises survey to be treated as supplied and subjected to tax determination under the prescribed statutory procedure. Direct confiscation proceedings cannot be used to impose tax, penalty and fine solely because excess or unaccounted stock is found; proceedings must instead be initiated under section 73 or 74. On that basis, the first appellate orders setting aside confiscation-based tax, penalty and fine were upheld, and the revenue appeals were dismissed.
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