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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Section 153C limitation requires the six-year look-back period to be calculated from the assessment year immediately preceding the year in which the satisfaction note is recorded. Where the satisfaction note was recorded in AY 2023-24, the period extended only to AY 2017-18; AY 2016-17 lay outside it. The notice for AY 2016-17 was therefore time-barred and quashed, and the writ petition succeeded.
Section 153C limitation requires the six-year look-back period to be calculated from the assessment year immediately preceding the year in which the satisfaction note is recorded. Where the satisfaction note was recorded in AY 2023-24, the period extended only to AY 2017-18; AY 2016-17 lay outside it. The notice for AY 2016-17 was therefore time-barred and quashed, and the writ petition succeeded.
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