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...
Section 12AB requires the Commissioner to grant or reject charitable-registration applications after examining objects, genuineness of activities and material legal compliance. It does not create a category of registration whose effectiveness or tax benefits are suspended pending future litigation. Conditions may operate only where they reflect statutory requirements; prescribed forms, rules and administrative circulars cannot enlarge substantive powers. Post-registration concerns must be addressed through the separate cancellation process, including inquiry and hearing safeguards. A binding jurisdictional ruling remains applicable unless stayed, modified or reversed. The absence of an express irrevocability clause does not itself establish that a public charitable trust is revocable where no power of revocation is reserved.
Section 12AB requires the Commissioner to grant or reject charitable-registration applications after examining objects, genuineness of activities and material legal compliance. It does not create a category of registration whose effectiveness or tax benefits are suspended pending future litigation. Conditions may operate only where they reflect statutory requirements; prescribed forms, rules and administrative circulars cannot enlarge substantive powers. Post-registration concerns must be addressed through the separate cancellation process, including inquiry and hearing safeguards. A binding jurisdictional ruling remains applicable unless stayed, modified or reversed. The absence of an express irrevocability clause does not itself establish that a public charitable trust is revocable where no power of revocation is reserved.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
