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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Misreporting penalties for under-reporting require identification of a specific statutory form of misreporting and evidence of its factual nexus with the assessee. Withdrawal of a political-party donation deduction after a reassessment notice, without more, does not establish misreporting. A political party's alleged general modus operandi is insufficient without material linking the assessee to the arrangement, return of the donation in cash, or knowing participation in an accommodation-entry transaction. On these facts, the enhanced penalty for misreporting was deleted.
Misreporting penalties for under-reporting require identification of a specific statutory form of misreporting and evidence of its factual nexus with the assessee. Withdrawal of a political-party donation deduction after a reassessment notice, without more, does not establish misreporting. A political party's alleged general modus operandi is insufficient without material linking the assessee to the arrangement, return of the donation in cash, or knowing participation in an accommodation-entry transaction. On these facts, the enhanced penalty for misreporting was deleted.
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