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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Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.
Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.
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