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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Section 270A excludes an amount from under-reported income where the taxpayer gives a bona fide explanation and fully discloses material facts needed to support it. Rejection of a claim in quantum proceedings does not itself establish false particulars, concealment, or lack of bona fides. Software-development expenditure and its accounting treatment disclosed in audited financial statements may therefore remain eligible for exclusion where the dispute concerns the debatable legal characterisation of the expenditure as revenue expenditure or capital loss. On the stated facts, the statutory exclusion applied and the penalty was deleted.
Section 270A excludes an amount from under-reported income where the taxpayer gives a bona fide explanation and fully discloses material facts needed to support it. Rejection of a claim in quantum proceedings does not itself establish false particulars, concealment, or lack of bona fides. Software-development expenditure and its accounting treatment disclosed in audited financial statements may therefore remain eligible for exclusion where the dispute concerns the debatable legal characterisation of the expenditure as revenue expenditure or capital loss. On the stated facts, the statutory exclusion applied and the penalty was deleted.
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