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...
Amended section 115UB deems non-business losses accumulated by an investment fund up to 31 March 2019 to be losses of unit holders holding units on that date. Unit holders may therefore carry forward their proportionate attributed share under the amended regime, rather than the fund retaining those losses. The disallowance of such carry-forward was set aside, subject to verification of the unit holder's factual entitlement and the losses attributed by the investment fund.
Amended section 115UB deems non-business losses accumulated by an investment fund up to 31 March 2019 to be losses of unit holders holding units on that date. Unit holders may therefore carry forward their proportionate attributed share under the amended regime, rather than the fund retaining those losses. The disallowance of such carry-forward was set aside, subject to verification of the unit holder's factual entitlement and the losses attributed by the investment fund.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
