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...
Additional evidence before the Tribunal may be filed under Rule 18(4) of the Income Tax Appellate Tribunal Rules, 1963 through a separate paper book supported by an application explaining the reasons. The High Court upheld admission of records retrieved after loss, damage or soiling, particularly because the Assessing Officer had incorrectly recorded that no material was produced. The Tribunal's findings on unexplained cash credits and trading liabilities were based on confirmations, transaction details, tax-deduction certificates, books of account and bank records. As reasoned factual findings disclosed no perversity, no substantial question of law arose and the Revenue's appeal was dismissed.
Additional evidence before the Tribunal may be filed under Rule 18(4) of the Income Tax Appellate Tribunal Rules, 1963 through a separate paper book supported by an application explaining the reasons. The High Court upheld admission of records retrieved after loss, damage or soiling, particularly because the Assessing Officer had incorrectly recorded that no material was produced. The Tribunal's findings on unexplained cash credits and trading liabilities were based on confirmations, transaction details, tax-deduction certificates, books of account and bank records. As reasoned factual findings disclosed no perversity, no substantial question of law arose and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
