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 144C requires a draft assessment order before a final reassessment order imposes a prejudicial variation on a non-resident eligible assessee. Following the amendment to the definition of eligible assessee, non-residents other than companies are expressly covered. The draft procedure allows the assessee to accept the variation or seek directions from the Dispute Resolution Panel. Direct issuance of a final reassessment order without a draft order deprives the assessee of that statutory remedy. Such non-compliance is a jurisdictional defect rather than a curable procedural irregularity, rendering the final reassessment order invalid.
Section 144C requires a draft assessment order before a final reassessment order imposes a prejudicial variation on a non-resident eligible assessee. Following the amendment to the definition of eligible assessee, non-residents other than companies are expressly covered. The draft procedure allows the assessee to accept the variation or seek directions from the Dispute Resolution Panel. Direct issuance of a final reassessment order without a draft order deprives the assessee of that statutory remedy. Such non-compliance is a jurisdictional defect rather than a curable procedural irregularity, rendering the final reassessment order invalid.
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