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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Recording satisfaction during assessment proceedings is required before penalty for an alleged cash-receipt contravention of section 269SS can be validly initiated. Applying the Supreme Court principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of any satisfaction or penalty initiation in the assessment order as an invalid assumption of jurisdiction. It deleted the penalty under section 271D without deciding whether section 269SS applied to cash sale consideration for immovable property.
Recording satisfaction during assessment proceedings is required before penalty for an alleged cash-receipt contravention of section 269SS can be validly initiated. Applying the Supreme Court principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of any satisfaction or penalty initiation in the assessment order as an invalid assumption of jurisdiction. It deleted the penalty under section 271D without deciding whether section 269SS applied to cash sale consideration for immovable property.
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