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 80GGC deduction depends on proving that a payment to a political party was a genuine contribution. Payment through banking channels and the recipient's registration are relevant but not conclusive. Genuineness may be assessed through the test of human probabilities, including evidence that the donee issued false receipts or returned donations, inconsistencies in the claim, incomplete bank records, failure to provide requested information, and non-response to enquiries. On such cumulative material, a deduction may be disallowed without relying solely on third-party statements. A challenge limited to the initiation of penalty proceedings is premature.
Section 80GGC deduction depends on proving that a payment to a political party was a genuine contribution. Payment through banking channels and the recipient's registration are relevant but not conclusive. Genuineness may be assessed through the test of human probabilities, including evidence that the donee issued false receipts or returned donations, inconsistencies in the claim, incomplete bank records, failure to provide requested information, and non-response to enquiries. On such cumulative material, a deduction may be disallowed without relying solely on third-party statements. A challenge limited to the initiation of penalty proceedings is premature.
Note: It is a system-generated summary and is for quick reference only.