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...
Cancellation of charitable-trust registration under section 12AA(3) depends on whether activities are non-genuine or conducted contrary to charitable objects. Registration proceedings assess the institution's charitable character and overall conduct, while alleged irregular receipts or income application in specified years are matters for assessment proceedings. Alleged capitation fees supported only by uncorroborated material recovered from third parties do not, without evidence of institutional receipt, establish that the trust's activities as a whole are non-genuine. Continuing educational and medical services, scholarships, and free treatment remain relevant to the genuineness inquiry.
Cancellation of charitable-trust registration under section 12AA(3) depends on whether activities are non-genuine or conducted contrary to charitable objects. Registration proceedings assess the institution's charitable character and overall conduct, while alleged irregular receipts or income application in specified years are matters for assessment proceedings. Alleged capitation fees supported only by uncorroborated material recovered from third parties do not, without evidence of institutional receipt, establish that the trust's activities as a whole are non-genuine. Continuing educational and medical services, scholarships, and free treatment remain relevant to the genuineness inquiry.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
