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...
Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.
Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
