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...
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
