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...
Withdrawal directions permitting an appellant to seek a court-deposited amount "subject to entitlement" must be read by reference to the party designations in the relevant civil appeal. The appellant in the Supreme Court appeal was therefore eligible to apply for release of the deposit, while the corporate debtor, as respondent and depositor, was not. The corporate debtor's withdrawal request was rejected, and the fixed-deposit amount was directed to be remitted to the appellant.
Withdrawal directions permitting an appellant to seek a court-deposited amount "subject to entitlement" must be read by reference to the party designations in the relevant civil appeal. The appellant in the Supreme Court appeal was therefore eligible to apply for release of the deposit, while the corporate debtor, as respondent and depositor, was not. The corporate debtor's withdrawal request was rejected, and the fixed-deposit amount was directed to be remitted to the appellant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
