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...
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Section 54F permits acquisition of a new residential asset within one year before transfer of the original asset and does not require that sale consideration alone fund the purchase. Where the flat is acquired within that period and the investment exceeds the capital gain, housing-loan financing does not disqualify the exemption; the capital-gain addition does not survive. Unexplained cash deposits remain liable to addition where the taxpayer produces no documentary evidence of source, fails to rebut adverse findings, and gives inconsistent explanations.
Section 54F permits acquisition of a new residential asset within one year before transfer of the original asset and does not require that sale consideration alone fund the purchase. Where the flat is acquired within that period and the investment exceeds the capital gain, housing-loan financing does not disqualify the exemption; the capital-gain addition does not survive. Unexplained cash deposits remain liable to addition where the taxpayer produces no documentary evidence of source, fails to rebut adverse findings, and gives inconsistent explanations.
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