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...
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...
Income of a substantially State-funded educational university...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exemption.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Income of a substantially State-funded educational university was exempt under section 10(23C)(iiiab), removing the requirement for a tax audit under section 44AB. As the audit obligation did not apply, penalty under section 271B for failure to obtain an audit was inapplicable. Tax-audit penalties for both assessment years were therefore deleted.
Income of a substantially State-funded educational university was exempt under section 10(23C)(iiiab), removing the requirement for a tax audit under section 44AB. As the audit obligation did not apply, penalty under section 271B for failure to obtain an audit was inapplicable. Tax-audit penalties for both assessment years were therefore deleted.
Note: It is a system-generated summary and is for quick reference only.