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...
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
