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...
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Different view taken by Court - Tribunal has already decided the matter in case of original petitioner - Once a decision has attained finality, it cannot be upset just on a mere ground that subsequently the higher forum has taken a different view - HC
Different view taken by Court - Tribunal has already decided the matter in case of original petitioner - Once a decision has attained finality, it cannot be upset just on a mere ground that subsequently the higher forum has taken a different view - HC
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