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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Following a search under section 132, assessment of search-related escaped income must proceed through the special reassessment mechanism under section 148 rather than the general scrutiny-assessment route under section 143(3). Consequently, a regular assessment made under section 143(3) for the relevant post-search assessment was treated as unsustainable in law and quashed, rendering the remaining grounds academic. The principle limits recourse to ordinary scrutiny assessment where the prescribed search-linked reassessment framework applies.
Following a search under section 132, assessment of search-related escaped income must proceed through the special reassessment mechanism under section 148 rather than the general scrutiny-assessment route under section 143(3). Consequently, a regular assessment made under section 143(3) for the relevant post-search assessment was treated as unsustainable in law and quashed, rendering the remaining grounds academic. The principle limits recourse to ordinary scrutiny assessment where the prescribed search-linked reassessment framework applies.
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