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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Deletion of reassessment additions through an appeal-effect order removed the basis for concealment penalty, as no concealed income remained when the penalty order was passed. The Tribunal therefore deleted the concealment penalty. Penalty for non-compliance with statutory notices was also deleted where the assessee had stated, through affidavits, unfamiliarity with tax law and reliance on a professional for compliance. The Tribunal treated these circumstances as warranting relief in the interest of justice, allowing both appeals and deleting both penalties.
Deletion of reassessment additions through an appeal-effect order removed the basis for concealment penalty, as no concealed income remained when the penalty order was passed. The Tribunal therefore deleted the concealment penalty. Penalty for non-compliance with statutory notices was also deleted where the assessee had stated, through affidavits, unfamiliarity with tax law and reliance on a professional for compliance. The Tribunal treated these circumstances as warranting relief in the interest of justice, allowing both appeals and deleting both penalties.
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