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...
Section 194B required the applicable threshold to be tested for each payment when made, without annual aggregation of a player's winnings. Player-funded payouts not claimed in the profit and loss account could not attract disallowance, and sponsored-prize disallowance required proof of an identified taxable payment without withholding. Deposit-linked and referral bonuses were promotional incentives rather than game winnings, so no withholding obligation arose. Corporate social responsibility payments otherwise qualifying as donations remained deductible under section 80G notwithstanding exclusion from business-expense deduction under section 37(1); employee stock option plan expenditure remained deductible. Income computation required verification of all subsisting assessment and appellate orders in chronological sequence, with remand for fresh computation.
Section 194B required the applicable threshold to be tested for each payment when made, without annual aggregation of a player's winnings. Player-funded payouts not claimed in the profit and loss account could not attract disallowance, and sponsored-prize disallowance required proof of an identified taxable payment without withholding. Deposit-linked and referral bonuses were promotional incentives rather than game winnings, so no withholding obligation arose. Corporate social responsibility payments otherwise qualifying as donations remained deductible under section 80G notwithstanding exclusion from business-expense deduction under section 37(1); employee stock option plan expenditure remained deductible. Income computation required verification of all subsisting assessment and appellate orders in chronological sequence, with remand for fresh computation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
