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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Documentary substantiation governed the disputed tax claims and electronic-record addition. Children's tuition-fee deduction was confined to payments supported by receipts, while the unsupported balance was disallowed because the claimant did not discharge the burden of proof. House rent allowance exemption was also disallowed for lack of supporting evidence. The challenge alleging inadequate hearing failed because four appellate notices were not complied with. Seized Excel entries identifying amounts as loans received from the assessee supported the unexplained-investment addition, as no material established that the entries were wrongly classified or represented company business transactions.
Documentary substantiation governed the disputed tax claims and electronic-record addition. Children's tuition-fee deduction was confined to payments supported by receipts, while the unsupported balance was disallowed because the claimant did not discharge the burden of proof. House rent allowance exemption was also disallowed for lack of supporting evidence. The challenge alleging inadequate hearing failed because four appellate notices were not complied with. Seized Excel entries identifying amounts as loans received from the assessee supported the unexplained-investment addition, as no material established that the entries were wrongly classified or represented company business transactions.
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