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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Limited Scrutiny confines the Assessing Officer's enquiry to the CASS issue notified to the assessee unless prescribed safeguards permit examination of an additional issue. A deduction for donations for scientific research and expenditure on an assessee's own in-house R&D facility are distinct statutory claims, notwithstanding their connection with section 35. The notified donation issue could not be expanded to review the in-house R&D deduction without credible specific information, recorded reasons, prior approval and required intimation. Participation in proceedings, a questionnaire, Form No. 3CL, or curative provisions could not create jurisdiction. The resulting disallowance under section 35(2AB) was deleted.
Limited Scrutiny confines the Assessing Officer's enquiry to the CASS issue notified to the assessee unless prescribed safeguards permit examination of an additional issue. A deduction for donations for scientific research and expenditure on an assessee's own in-house R&D facility are distinct statutory claims, notwithstanding their connection with section 35. The notified donation issue could not be expanded to review the in-house R&D deduction without credible specific information, recorded reasons, prior approval and required intimation. Participation in proceedings, a questionnaire, Form No. 3CL, or curative provisions could not create jurisdiction. The resulting disallowance under section 35(2AB) was deleted.
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