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...
Revision u/s 263 by CIT - limited scrutiny assessment - Based on the information mentioned in the revisionary order, the learned PCIT should have reprimanded the assessing officer by asking assessee to furnish the information, which were not within the scope of limited scrutiny. Instead of that, PCIT has invoked the provisions of Section 263 on such information. - AT
Revision u/s 263 by CIT - limited scrutiny assessment - Based on the information mentioned in the revisionary order, the learned PCIT should have reprimanded the assessing officer by asking assessee to furnish the information, which were not within the scope of limited scrutiny. Instead of that, PCIT has invoked the provisions of Section 263 on such information. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4929 
