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...
Input tax credit for invoices from the covered period is regularised under section 16(5), retrospectively effective from 1 July 2017, where the relevant returns were filed by 30 November 2021. Credit relating to July 2018 through March 2020, including financial year 2019-20 invoices, cannot be denied solely because returns were filed after the original deadline. Orders denying the credit were quashed and remitted for re-adjudication under section 16(5) after hearing, including reconsideration of Electronic Credit Ledger blocking. Further coercive action was restrained pending re-adjudication.
Input tax credit for invoices from the covered period is regularised under section 16(5), retrospectively effective from 1 July 2017, where the relevant returns were filed by 30 November 2021. Credit relating to July 2018 through March 2020, including financial year 2019-20 invoices, cannot be denied solely because returns were filed after the original deadline. Orders denying the credit were quashed and remitted for re-adjudication under section 16(5) after hearing, including reconsideration of Electronic Credit Ledger blocking. Further coercive action was restrained pending re-adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
