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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Filing a first appeal against a disputed tax demand does not automatically stay recovery. A stay requires valid reasons and a specific stay petition; where no petition was filed before recovery, the taxpayer cannot claim a stay as of right or obtain refund merely because the appeal remained pending. Refund of the amount already recovered was therefore declined. However, substantial recovery already made may justify protection against further coercive recovery until disposal of the first appeal.
Filing a first appeal against a disputed tax demand does not automatically stay recovery. A stay requires valid reasons and a specific stay petition; where no petition was filed before recovery, the taxpayer cannot claim a stay as of right or obtain refund merely because the appeal remained pending. Refund of the amount already recovered was therefore declined. However, substantial recovery already made may justify protection against further coercive recovery until disposal of the first appeal.
Note: It is a system-generated summary and is for quick reference only.
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