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...
Advance for rent and never turned into income - Recovery barred by limitation - still remains as a liability in its account - If the recovery had been barred by limitation, necessarily, it has to be treated as an income from the business. It could not have been treated as an unexplained cash credit or as an unexplained investment, since the source was clear and there was proper explanation for the amounts as seen from the books of accounts.
Advance for rent and never turned into income - Recovery barred by limitation - still remains as a liability in its account - If the recovery had been barred by limitation, necessarily, it has to be treated as an income from the business. It could not have been treated as an unexplained cash credit or as an unexplained investment, since the source was clear and there was proper explanation for the amounts as seen from the books of accounts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4927 
