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...
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The case pertains to the prohibition of benami property transactions and the applicability of amended provisions introduced by the Amending Act of 2016 to the Benami Transactions (Prohibition) Act, 1988. The key points are: The Initiating Officer (I.O.) attached an agricultural land, alleging it to be a benami transaction, but could not identify the beneficial owner. The Adjudicating Authority treated the transaction as falling u/s 2(9A) of the amended Act, despite it being prior to the 2016 amendment. The Supreme Court has clarified that the amended provisions have prospective application. Transactions prior to November 1, 2016, not covered by Section 2(9A) of the amended Act, are governed by the judgment in Union of India & Anr. vs. M/s. Ganpati Dealcom Pvt. Ltd. An exception may apply if the case falls u/s 2(9A) of the amended definition, as per the Appellate Tribunal's judgment in M/s. Prism Scan Express Pvt. Ltd.
The case pertains to the prohibition of benami property transactions and the applicability of amended provisions introduced by the Amending Act of 2016 to the Benami Transactions (Prohibition) Act, 1988. The key points are: The Initiating Officer (I.O.) attached an agricultural land, alleging it to be a benami transaction, but could not identify the beneficial owner. The Adjudicating Authority treated the transaction as falling u/s 2(9A) of the amended Act, despite it being prior to the 2016 amendment. The Supreme Court has clarified that the amended provisions have prospective application. Transactions prior to November 1, 2016, not covered by Section 2(9A) of the amended Act, are governed by the judgment in Union of India & Anr. vs. M/s. Ganpati Dealcom Pvt. Ltd. An exception may apply if the case falls u/s 2(9A) of the amended definition, as per the Appellate Tribunal's judgment in M/s. Prism Scan Express Pvt. Ltd.
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