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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Jai Research Foundation is approved as a Research Association...
Scientific research approval grants a research association tax recognition, subject to annual donor reporting, certification, and regulatory compliance.
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Jai Research Foundation is approved as a Research Association for scientific research under section 45(4)(b), for the purposes of section 45(3)(a)(i) and Income-tax Rules 32 and 33. The approval applies for tax years 2026-2027 through 2030-2031, subject to compliance with rule 33. For each tax year in which donations are received, the association must prepare and deliver Form 15 by 31 May following that tax year. It must also provide each donor with a Form 16 certificate specifying the donation amount.
Jai Research Foundation is approved as a Research Association for scientific research under section 45(4)(b), for the purposes of section 45(3)(a)(i) and Income-tax Rules 32 and 33. The approval applies for tax years 2026-2027 through 2030-2031, subject to compliance with rule 33. For each tax year in which donations are received, the association must prepare and deliver Form 15 by 31 May following that tax year. It must also provide each donor with a Form 16 certificate specifying the donation amount.
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