Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
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...
Co-accused statements and WhatsApp-chat material cannot support customs penalties where the statements lack independent corroboration, the makers are not cross-examined, and electronic data from a seized phone is not reliable or cogent. Penalties for assisting import of concealed prohibited or misdeclared goods require proof that the person knowingly abetted conduct rendering goods liable to confiscation. Penalties for false declarations additionally require knowing or intentional use of materially false documents. Without proof of knowledge, deliberate conduct, or false declaration, the penalties were set aside.
Co-accused statements and WhatsApp-chat material cannot support customs penalties where the statements lack independent corroboration, the makers are not cross-examined, and electronic data from a seized phone is not reliable or cogent. Penalties for assisting import of concealed prohibited or misdeclared goods require proof that the person knowingly abetted conduct rendering goods liable to confiscation. Penalties for false declarations additionally require knowing or intentional use of materially false documents. Without proof of knowledge, deliberate conduct, or false declaration, the penalties were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
