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...
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4908 
