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...
Appeals from Tribunal orders determining customs classification, the rate of customs duty, or the value of goods for assessment fall outside High Court appellate jurisdiction under section 130. The prescribed appellate remedy for such disputes is an appeal to the Supreme Court under section 130E. Consequently, a High Court appeal challenging imported-goods classification and consequential customs duty liability is not maintainable and must be pursued before the Supreme Court.
Appeals from Tribunal orders determining customs classification, the rate of customs duty, or the value of goods for assessment fall outside High Court appellate jurisdiction under section 130. The prescribed appellate remedy for such disputes is an appeal to the Supreme Court under section 130E. Consequently, a High Court appeal challenging imported-goods classification and consequential customs duty liability is not maintainable and must be pursued before the Supreme Court.
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TaxTMI 
TaxTMI 
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