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...
Effective 1 October 2026, the TDS compliance framework extends to consideration for transfer of immovable property where a resident individual or HUF must deduct tax under section 393(2). Rules 215, 218 and 219 now require the relevant TDS certificate, deposit and statement reporting for such transactions. Form 132 and Form 141 are amended to cover property transfers involving non-resident sellers and resident individual or HUF buyers. New Schedule E in Form 141 requires property, buyer, seller, consideration, instalment and tax-deduction details. Non-resident seller reporting requires contact details, overseas address, tax residency certificate and tax identification information, including where PAN is unavailable.
Effective 1 October 2026, the TDS compliance framework extends to consideration for transfer of immovable property where a resident individual or HUF must deduct tax under section 393(2). Rules 215, 218 and 219 now require the relevant TDS certificate, deposit and statement reporting for such transactions. Form 132 and Form 141 are amended to cover property transfers involving non-resident sellers and resident individual or HUF buyers. New Schedule E in Form 141 requires property, buyer, seller, consideration, instalment and tax-deduction details. Non-resident seller reporting requires contact details, overseas address, tax residency certificate and tax identification information, including where PAN is unavailable.
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