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...
Post-detection surrender of depreciation and amortisation claims arising from dealings with a non-genuine supplier was treated as non-voluntary where survey findings and adverse material had exposed accommodation entries, the original return claimed the expenditure, and no revised return correctly disclosed income. Failure to prove the supplier's existence supported misreporting through suppression of facts and false entries; a surrender to buy peace or avoid litigation after detection did not preclude penalty for under-reported income. A challenge that the penalty notice omitted the specific misreporting clause was rejected because it had not been raised before the assessing or appellate authorities or through grounds before the Tribunal. The penalty was sustained and the appeal dismissed.
Post-detection surrender of depreciation and amortisation claims arising from dealings with a non-genuine supplier was treated as non-voluntary where survey findings and adverse material had exposed accommodation entries, the original return claimed the expenditure, and no revised return correctly disclosed income. Failure to prove the supplier's existence supported misreporting through suppression of facts and false entries; a surrender to buy peace or avoid litigation after detection did not preclude penalty for under-reported income. A challenge that the penalty notice omitted the specific misreporting clause was rejected because it had not been raised before the assessing or appellate authorities or through grounds before the Tribunal. The penalty was sustained and the appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
