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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Revision under section 263 is unavailable where the Assessing Officer has examined a claimed exemption, considered supporting explanations and adopted a plausible view; a different view of the revisional authority does not establish an order that is both erroneous and prejudicial to the Revenue. Interest awarded under section 28 of the Land Acquisition Act for delayed payment of enhanced compensation on compulsorily acquired agricultural land was treated by the majority as an accretion to compensation rather than income from other sources. Accordingly, the revisionary order was quashed and the receipt was not assessed under that head.
Revision under section 263 is unavailable where the Assessing Officer has examined a claimed exemption, considered supporting explanations and adopted a plausible view; a different view of the revisional authority does not establish an order that is both erroneous and prejudicial to the Revenue. Interest awarded under section 28 of the Land Acquisition Act for delayed payment of enhanced compensation on compulsorily acquired agricultural land was treated by the majority as an accretion to compensation rather than income from other sources. Accordingly, the revisionary order was quashed and the receipt was not assessed under that head.
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