Transfer-pricing rules apply to dealings between an Indian...

Transfer-pricing rules apply to dealings between an Indian permanent establishment and its Head Office or overseas branches. An Additional Commissioner may act as Transfer Pricing Officer where included within the definition of Joint Commissioner and no lack of authorisation is shown. Closely linked money-market placements may be aggregated, while the Transfer Pricing Officer cannot determine the year in which income accrues. Separate remuneration for correspondent banking or incidental supervisory functions requires proof of a distinct service, resources, benefit and cost base. Profit Split Method attribution requires combined-profit analysis and allocation based on functions, assets and risks. Separately, broken-period interest on stock-in-trade securities is deductible, and unrealised profit on executory forward contracts is not taxable without real accrual.