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...
Unrecorded cash paid as on-money for commercial property, where established on the evidentiary standard applicable to income-tax proceedings, is taxable only to the extent of the profit element embedded in the payment, since income tax applies to income rather than gross receipts. The assessable addition was confined to 10% of the unrecorded payment and made taxable at normal income-tax rates rather than under section 115BBE.
Unrecorded cash paid as on-money for commercial property, where established on the evidentiary standard applicable to income-tax proceedings, is taxable only to the extent of the profit element embedded in the payment, since income tax applies to income rather than gross receipts. The assessable addition was confined to 10% of the unrecorded payment and made taxable at normal income-tax rates rather than under section 115BBE.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
