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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Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.
Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.
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