Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
☰   Show Results ❯
    Omitted specified-domestic-transaction rules invalidated transfer-pricing adjustments, while derivative losses and exempt-income expenditure limits re...
    Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
    MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
    Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.
    Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
    Notional interest on delayed trade receivables may be deleted when financial records verify the taxpayer is completely debt-free.
    Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
    Retracted search surrenders without corroboration cannot sustain undisclosed-income additions; no section 14A disallowance arises without exempt incom...
    Charitable trust registration cancellation requires proof of non-genuine activities, while year-specific irregular receipts remain assessment matters.
    Benami cash routing through third-party bank accounts permits attachment of remaining balances and traceable converted funds.
    Rectification jurisdiction excludes merits review where objections challenge concluded penalty findings rather than patent errors on the record.
    Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
    Customs reassessment acceptance preserves challenge rights where transaction value is rejected solely on unsupported NIDB data.
    Furnace re-lining refractories qualify as EPCG capital goods, securing zero-duty import benefits and eliminating related customs demands.
    Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
    Storage-server classification determines end-use Basic Customs Duty exemption for qualifying imported manufacturing inputs, subject to prescribed cond...
    Customs classification of battery insulating tape distinguishes dedicated die-cut accumulator parts from general-use self-adhesive rolls.
    Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
    Recall jurisdiction cannot cure affidavit defects or permit non-parties in disciplinary stay proceedings as parties.
    Credit-rating conflict safeguards extend to promoter borrowers and subsidiaries, invalidating penalties based on a narrower interpretation.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Back

All Highlights

Cost-to-cost recovery of salary and travel expenses for...

Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allowed.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Income Tax October 13, 2026 Case Laws AT
Cost-to-cost recovery of salary and travel expenses for employees temporarily seconded to associated enterprises constitutes expense reimbursement rather than consideration for margin-bearing services where recovered exactly at cost. Accordingly, the transfer-pricing mark-up adjustment was deleted, supported by consistent treatment in other years and a bilateral Advance Pricing Agreement allowing recovery at cost. Amalgamation expenditure incurred after approval is amortised over five years beginning in the assessment year relevant to the year of expenditure, not the appointed amalgamation date. The fifth annual deduction was allowed because the claim had been accepted for the prior four years without changed facts.

Topics

Acts Income Tax