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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Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.
Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.
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