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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Goodwill arising from the slump-sale acquisition of a going software business division qualifies as a depreciable intangible asset where the Business Transfer Agreement transfers the division's products, employees, licences, permits and assets. Consideration exceeding the net value of transferred assets and liabilities may represent goodwill and other intangible assets rather than unexplained expenditure, where it is recorded under the transfer agreement and not claimed as revenue expenditure. Tax deduction at source on transfer of immovable property does not apply where the transferred business assets comprise computer systems and intangible assets, with no land, building or part of a building transferred. Depreciation and deletion of the related disallowance and addition were sustained.
Goodwill arising from the slump-sale acquisition of a going software business division qualifies as a depreciable intangible asset where the Business Transfer Agreement transfers the division's products, employees, licences, permits and assets. Consideration exceeding the net value of transferred assets and liabilities may represent goodwill and other intangible assets rather than unexplained expenditure, where it is recorded under the transfer agreement and not claimed as revenue expenditure. Tax deduction at source on transfer of immovable property does not apply where the transferred business assets comprise computer systems and intangible assets, with no land, building or part of a building transferred. Depreciation and deletion of the related disallowance and addition were sustained.
Note: It is a system-generated summary and is for quick reference only.
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