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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Tariff-related debit notes seeking reimbursement of income tax as an electricity-tariff component involve disputed questions requiring specialised adjudication before CERC. Writ jurisdiction did not extend to examining the merits of the debit notes or the claimed liability. The generating company was required to pursue the regulatory remedy before CERC, which was to decide the dispute expeditiously after hearing all parties. The writ petition was disposed of on that basis.
Tariff-related debit notes seeking reimbursement of income tax as an electricity-tariff component involve disputed questions requiring specialised adjudication before CERC. Writ jurisdiction did not extend to examining the merits of the debit notes or the claimed liability. The generating company was required to pursue the regulatory remedy before CERC, which was to decide the dispute expeditiously after hearing all parties. The writ petition was disposed of on that basis.
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TaxTMI 
TaxTMI 
of 4918 
