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...
Territorial jurisdiction over customs seizure and provisional release depends on where the material cause of action arises. When the seizure of imported goods and release proceedings occur at ICD Dadri under the Customs Commissionerate at Noida, neither the Delhi location of CBIC or DRI headquarters nor disputes over classification or a Chartered Engineer's certificate creates jurisdiction in Delhi. Absence of any part of the cause of action is a jurisdictional defect, rather than a basis for applying forum conveniens, requiring recourse to the appropriate forum.
Territorial jurisdiction over customs seizure and provisional release depends on where the material cause of action arises. When the seizure of imported goods and release proceedings occur at ICD Dadri under the Customs Commissionerate at Noida, neither the Delhi location of CBIC or DRI headquarters nor disputes over classification or a Chartered Engineer's certificate creates jurisdiction in Delhi. Absence of any part of the cause of action is a jurisdictional defect, rather than a basis for applying forum conveniens, requiring recourse to the appropriate forum.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
