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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Joint Commissioners of Income-tax (Appeals) and Additional Commissioners of Income-tax (Appeals) are placed under the control of the Principal Chief Commissioners of Income-tax or Chief Commissioners of Income-tax within whose jurisdiction they perform their functions. This substitutes the existing clause governing their subordination under the 1988 notification and takes effect from 30 September 2026, the date of publication in the Official Gazette.
Joint Commissioners of Income-tax (Appeals) and Additional Commissioners of Income-tax (Appeals) are placed under the control of the Principal Chief Commissioners of Income-tax or Chief Commissioners of Income-tax within whose jurisdiction they perform their functions. This substitutes the existing clause governing their subordination under the 1988 notification and takes effect from 30 September 2026, the date of publication in the Official Gazette.
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