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...
Compulsory-acquisition compensation for agricultural land in the Hazira Notified Area was not chargeable to capital-gains tax because the land lay outside a municipal area, retained its agricultural character, and was used for agricultural operations. The resulting capital-gains addition on land compensation did not survive. For compensation attributable to built-up structures and other assets acquired with the land, 60 per cent of the relevant compensation was allowable as cost of acquisition when computing consequential capital gains.
Compulsory-acquisition compensation for agricultural land in the Hazira Notified Area was not chargeable to capital-gains tax because the land lay outside a municipal area, retained its agricultural character, and was used for agricultural operations. The resulting capital-gains addition on land compensation did not survive. For compensation attributable to built-up structures and other assets acquired with the land, 60 per cent of the relevant compensation was allowable as cost of acquisition when computing consequential capital gains.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
