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...
Statutory timelines for disposal of income-tax appeals prevail over administrative circulars that assign priority categories for out-of-turn disposal. Where the prescribed timeline has not been followed, pending appeals must be decided expeditiously and cannot be deferred solely because they do not fall within an administrative priority category. The appellate authority must provide a proper and reasonable opportunity of hearing and dispose of the pending appeals within three months, without adjudication of their merits at this stage.
Statutory timelines for disposal of income-tax appeals prevail over administrative circulars that assign priority categories for out-of-turn disposal. Where the prescribed timeline has not been followed, pending appeals must be decided expeditiously and cannot be deferred solely because they do not fall within an administrative priority category. The appellate authority must provide a proper and reasonable opportunity of hearing and dispose of the pending appeals within three months, without adjudication of their merits at this stage.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
