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...
Profit estimation on unrecorded ready-mix concrete sales must have a reasonable nexus to the material and cannot replace an accepted turnover working without supporting evidence. Where audited results for the same activity showed a gross loss and the books were neither rejected nor found defective, departing from the year-specific approach adopted in prior assessments was unsupported; the estimated gross-profit addition was deleted. Cash-credit provisions require a credit in the taxpayer's own books. Off-book pen-drive entries attributed to unrecorded sales could not support a cash-credit addition, particularly where taxing full receipts beyond their profit element would result in double assessment. The cash-credit addition was deleted.
Profit estimation on unrecorded ready-mix concrete sales must have a reasonable nexus to the material and cannot replace an accepted turnover working without supporting evidence. Where audited results for the same activity showed a gross loss and the books were neither rejected nor found defective, departing from the year-specific approach adopted in prior assessments was unsupported; the estimated gross-profit addition was deleted. Cash-credit provisions require a credit in the taxpayer's own books. Off-book pen-drive entries attributed to unrecorded sales could not support a cash-credit addition, particularly where taxing full receipts beyond their profit element would result in double assessment. The cash-credit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
