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...
Page of 4918
Press 'Enter' after typing page number.
341 to 360 of 98359 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
