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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GST refund disclosure in a tax audit report does not, by itself, establish taxable income. GST is a statutory levy collected and paid on behalf of the Government, and its refund represents a return of tax paid rather than income. Where refunded GST or IGST was not claimed as expenditure in the profit and loss account, it cannot be taxed solely because of its disclosure in the tax audit report. Allowability of the refund remains subject to examination of supporting records and applicable law.
GST refund disclosure in a tax audit report does not, by itself, establish taxable income. GST is a statutory levy collected and paid on behalf of the Government, and its refund represents a return of tax paid rather than income. Where refunded GST or IGST was not claimed as expenditure in the profit and loss account, it cannot be taxed solely because of its disclosure in the tax audit report. Allowability of the refund remains subject to examination of supporting records and applicable law.
Note: It is a system-generated summary and is for quick reference only.
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