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...
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Government securities held by a bank as stock-in-trade may be valued at cost or market value, whichever is lower. A consistently and regularly adopted valuation method cannot be displaced merely because the tax department prefers another method, supporting depreciation on such securities. Brokerage expenditure was allowable after the assessing authority accepted the claim on remand. Unclaimed bank balances do not constitute remission or cessation of a trading liability merely because customers have not claimed them; the bank's legal liability continues and the balances are not taxable on that basis. The departmental appeals were dismissed.
Government securities held by a bank as stock-in-trade may be valued at cost or market value, whichever is lower. A consistently and regularly adopted valuation method cannot be displaced merely because the tax department prefers another method, supporting depreciation on such securities. Brokerage expenditure was allowable after the assessing authority accepted the claim on remand. Unclaimed bank balances do not constitute remission or cessation of a trading liability merely because customers have not claimed them; the bank's legal liability continues and the balances are not taxable on that basis. The departmental appeals were dismissed.
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