Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
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...
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Retraction of a search surrender, when satisfactorily explained and unsupported by corroborative evidence, cannot alone sustain an undisclosed-income addition; the related addition was deleted. No section 14A disallowance arises where no exempt income was earned for the relevant year, and the later Explanation was prospective. Seizure of incriminating material permits assessment of total income under section 153A for completed years, including other issues. Interest for delayed remittance of tax deducted at source is compensatory and allowable as business expenditure. Depreciation on trucks used for own-goods transport must be computed at the lower prescribed rate on year-wise written-down value.
Retraction of a search surrender, when satisfactorily explained and unsupported by corroborative evidence, cannot alone sustain an undisclosed-income addition; the related addition was deleted. No section 14A disallowance arises where no exempt income was earned for the relevant year, and the later Explanation was prospective. Seizure of incriminating material permits assessment of total income under section 153A for completed years, including other issues. Interest for delayed remittance of tax deducted at source is compensatory and allowable as business expenditure. Depreciation on trucks used for own-goods transport must be computed at the lower prescribed rate on year-wise written-down value.
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TaxTMI 
TaxTMI 
