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...
Refund of unutilised input tax credit under the inverted duty structure remains available under section 54(3) where accumulation results from higher tax on certain inputs than on output supplies. Circular No. 135/05/2020 does not bar such a claim merely because one principal input and the output supply attract the same tax rate. The refund application must be considered under section 54(3), and time spent pursuing writ proceedings is excluded when calculating the limitation period.
Refund of unutilised input tax credit under the inverted duty structure remains available under section 54(3) where accumulation results from higher tax on certain inputs than on output supplies. Circular No. 135/05/2020 does not bar such a claim merely because one principal input and the output supply attract the same tax rate. The refund application must be considered under section 54(3), and time spent pursuing writ proceedings is excluded when calculating the limitation period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
