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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Section 119(2)(b) permits condonation of delay in a revised return seeking refund to prevent genuine hardship, subject to the prescribed six-year limit. The competent authority must independently determine whether the refund claim is correct and genuine and whether genuine hardship exists; this power cannot be exercised routinely. A rejection cannot rest on irrelevant considerations or an unreasoned denial of hardship, and recorded reasons cannot be supplemented in court. The sufficient-cause standard for delayed appeals under the Limitation Act does not impose a stand-alone requirement to explain delay under section 119(2)(b). The refusal to condone was quashed and remitted for a fresh reasoned decision, leaving the exemption claim open.
Section 119(2)(b) permits condonation of delay in a revised return seeking refund to prevent genuine hardship, subject to the prescribed six-year limit. The competent authority must independently determine whether the refund claim is correct and genuine and whether genuine hardship exists; this power cannot be exercised routinely. A rejection cannot rest on irrelevant considerations or an unreasoned denial of hardship, and recorded reasons cannot be supplemented in court. The sufficient-cause standard for delayed appeals under the Limitation Act does not impose a stand-alone requirement to explain delay under section 119(2)(b). The refusal to condone was quashed and remitted for a fresh reasoned decision, leaving the exemption claim open.
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