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...
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
