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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Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.
Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.
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TaxTMI 
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