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...
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...
Customs Act penalties for facilitating undervalued imports require evidence that the person procured or used an IEC, participated in unlawful import activity, or knew of it. Introducing an importer to a freight forwarder or providing contact details for a person able to arrange an IEC, without such evidence, does not establish a Customs Act violation or conspiracy. On that basis, penalties under Sections 112(a) and 114AA were set aside, with consequential relief.
Customs Act penalties for facilitating undervalued imports require evidence that the person procured or used an IEC, participated in unlawful import activity, or knew of it. Introducing an importer to a freight forwarder or providing contact details for a person able to arrange an IEC, without such evidence, does not establish a Customs Act violation or conspiracy. On that basis, penalties under Sections 112(a) and 114AA were set aside, with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
