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...
Tax deduction at source from compensation payable on compulsory land acquisition is treated as impermissible where it reduces compensation due to land losers. The legal point follows an earlier ruling barring income-tax/TDS withholding from such compensation. Any amount withheld as income tax/TDS is to be released to the affected land losers within three months.
Tax deduction at source from compensation payable on compulsory land acquisition is treated as impermissible where it reduces compensation due to land losers. The legal point follows an earlier ruling barring income-tax/TDS withholding from such compensation. Any amount withheld as income tax/TDS is to be released to the affected land losers within three months.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4939 
