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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Transfer-pricing benchmarking under TNMM required royalty for engine technology to remain aggregated with the manufacturing segment once TNMM had been accepted as the most appropriate method; separate royalty benchmarking was deleted for both assessment years. Engineering and design comparability required exclusion of a company with diversified services, no reliable segmental data, a different functional profile and an extraordinary acquisition; margins require recomputation. The expenditure disallowance relating to exempt dividend income was sustained under section 14A read with Rule 8D. Tax liability, credits and interest computations were remitted for verification and correction.
Transfer-pricing benchmarking under TNMM required royalty for engine technology to remain aggregated with the manufacturing segment once TNMM had been accepted as the most appropriate method; separate royalty benchmarking was deleted for both assessment years. Engineering and design comparability required exclusion of a company with diversified services, no reliable segmental data, a different functional profile and an extraordinary acquisition; margins require recomputation. The expenditure disallowance relating to exempt dividend income was sustained under section 14A read with Rule 8D. Tax liability, credits and interest computations were remitted for verification and correction.
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