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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Regional Rural Banks are deemed to be co-operative societies for Income-tax Act purposes under the statutory fiction in section 22 of the Regional Rural Banks Act. That fiction remains effective because section 80P(4) does not displace it, and definitions of primary co-operative bank or primary credit society are inapplicable where the bank is not claimed to fall within those categories. Deduction under section 80P is therefore available. An assessment correctly granting that deduction is not erroneous and prejudicial to the interests of the Revenue, limiting revision under section 263.
Regional Rural Banks are deemed to be co-operative societies for Income-tax Act purposes under the statutory fiction in section 22 of the Regional Rural Banks Act. That fiction remains effective because section 80P(4) does not displace it, and definitions of primary co-operative bank or primary credit society are inapplicable where the bank is not claimed to fall within those categories. Deduction under section 80P is therefore available. An assessment correctly granting that deduction is not erroneous and prejudicial to the interests of the Revenue, limiting revision under section 263.
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