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...
Preferential customs duty under the ASEAN-India arrangement requires proof that goods satisfy the applicable origin rules; a country-of-origin certificate does not remove the importer's duty of reasonable care. Origin verification must be certificate- and consignment-specific: an adverse foreign communication concerning identified unauthentic certificates cannot, without evidence linking other certificates to the defect or showing their cancellation or revocation, justify denial of benefits for those certificates. Importers must retain origin-related information and supporting records, while customs must undertake focused verification and identify the precise alleged defect. Preferential treatment may be denied for incomplete or non-conforming proof, or where origin requirements or misrepresentation are independently established.
Preferential customs duty under the ASEAN-India arrangement requires proof that goods satisfy the applicable origin rules; a country-of-origin certificate does not remove the importer's duty of reasonable care. Origin verification must be certificate- and consignment-specific: an adverse foreign communication concerning identified unauthentic certificates cannot, without evidence linking other certificates to the defect or showing their cancellation or revocation, justify denial of benefits for those certificates. Importers must retain origin-related information and supporting records, while customs must undertake focused verification and identify the precise alleged defect. Preferential treatment may be denied for incomplete or non-conforming proof, or where origin requirements or misrepresentation are independently established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
