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...
Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.
Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
