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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Upper turnover filter of Rs. 200 crore for selecting software-development comparables in transfer-pricing analysis was treated as valid under precedent. The Revenue's challenge failed because the issue was already covered in favour of the taxpayer, resulting in dismissal of its appeal for the relevant assessment year.
Upper turnover filter of Rs. 200 crore for selecting software-development comparables in transfer-pricing analysis was treated as valid under precedent. The Revenue's challenge failed because the issue was already covered in favour of the taxpayer, resulting in dismissal of its appeal for the relevant assessment year.
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