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...
Enhanced penalty for misreporting under section 270A requires proof from the assessee's own conduct that it misrepresented or suppressed facts or furnished false particulars. Mere disallowance of a deduction for political contributions under section 80GGC does not establish misreporting where the claim and banking-channel payment were disclosed and not disproved. General investigation findings concerning the recipient political party cannot replace an independent penalty inquiry. The penalty for alleged misreporting was deleted.
Enhanced penalty for misreporting under section 270A requires proof from the assessee's own conduct that it misrepresented or suppressed facts or furnished false particulars. Mere disallowance of a deduction for political contributions under section 80GGC does not establish misreporting where the claim and banking-channel payment were disclosed and not disproved. General investigation findings concerning the recipient political party cannot replace an independent penalty inquiry. The penalty for alleged misreporting was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
