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...
Incorrect selection of an applicable clause or code in Form 10AB for charitable registration or approval, when bona fide and inadvertent, warrants an opportunity for rectification rather than rejection solely on that technical ground. Where provisional registration has been granted on the same application, the technical error should not prevent consideration on merits. Applications may be reconsidered after correction of the form and a proper hearing, ensuring that procedural defects do not defeat substantive eligibility.
Incorrect selection of an applicable clause or code in Form 10AB for charitable registration or approval, when bona fide and inadvertent, warrants an opportunity for rectification rather than rejection solely on that technical ground. Where provisional registration has been granted on the same application, the technical error should not prevent consideration on merits. Applications may be reconsidered after correction of the form and a proper hearing, ensuring that procedural defects do not defeat substantive eligibility.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
