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...
GST registration of a rented additional place of business must be assessed by verifying the premises, the applicant's business use or storage, and prescribed occupancy documents; ownership disputes, third-party complaints, and absence of a civil decree cannot be made conditions for registration. For rented premises, a rent or lease agreement and specified ownership-supporting documentation are required, but conclusive title proof or an original lease held by a civil court is unnecessary; deficiencies must be specifically notified. Reliance on undisclosed post-hearing third-party material and failure to address material documents breach natural justice and reasoned decision-making. Rejection and appellate action were set aside, with limited remand for fresh verification without deciding title or lease validity.
GST registration of a rented additional place of business must be assessed by verifying the premises, the applicant's business use or storage, and prescribed occupancy documents; ownership disputes, third-party complaints, and absence of a civil decree cannot be made conditions for registration. For rented premises, a rent or lease agreement and specified ownership-supporting documentation are required, but conclusive title proof or an original lease held by a civil court is unnecessary; deficiencies must be specifically notified. Reliance on undisclosed post-hearing third-party material and failure to address material documents breach natural justice and reasoned decision-making. Rejection and appellate action were set aside, with limited remand for fresh verification without deciding title or lease validity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
