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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Scientific-research approval is granted to Bhartiya Sanskriti Darshan Trust under the university, college or other institution category for the statutory donation-related provisions. Its continued applicability requires uninterrupted Scientific and Industrial Research Organisation approval for each effective tax year, compliance with prescribed conditions, annual filing of Form No. 15 by 31 May following the tax year in which donations are received, and issuance of Form No. 16 donation certificates to donors. The approval applies for tax years 2026-2027 through 2030-2031.
Scientific-research approval is granted to Bhartiya Sanskriti Darshan Trust under the university, college or other institution category for the statutory donation-related provisions. Its continued applicability requires uninterrupted Scientific and Industrial Research Organisation approval for each effective tax year, compliance with prescribed conditions, annual filing of Form No. 15 by 31 May following the tax year in which donations are received, and issuance of Form No. 16 donation certificates to donors. The approval applies for tax years 2026-2027 through 2030-2031.
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