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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Jurisdiction over an amalgamating company ends when it ceases to exist following amalgamation. A section 201 order issued and served in the former company's name, despite prior notification to the TDS authority, suffers a jurisdictional defect; referring to the successor company in the body of the order does not cure it. The order was void ab initio and quashed, while the issue of interest under section 201(1A) remained academic.
Jurisdiction over an amalgamating company ends when it ceases to exist following amalgamation. A section 201 order issued and served in the former company's name, despite prior notification to the TDS authority, suffers a jurisdictional defect; referring to the successor company in the body of the order does not cure it. The order was void ab initio and quashed, while the issue of interest under section 201(1A) remained academic.
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