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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Computer software licence payments fall within the royalty clarification only prospectively from 1 April 2012. Tax deducted on payments to foreign suppliers does not, by itself, establish taxability of comparable payments to domestic suppliers, which require independent examination; consequently, the stated software licence renewals attracted no tax-deduction disallowance. For tax-deduction disallowance, "payable" includes amounts already paid. One-time non-refundable membership fees are recognised over the membership period, supporting apportioned recognition rather than immediate treatment in full.
Computer software licence payments fall within the royalty clarification only prospectively from 1 April 2012. Tax deducted on payments to foreign suppliers does not, by itself, establish taxability of comparable payments to domestic suppliers, which require independent examination; consequently, the stated software licence renewals attracted no tax-deduction disallowance. For tax-deduction disallowance, "payable" includes amounts already paid. One-time non-refundable membership fees are recognised over the membership period, supporting apportioned recognition rather than immediate treatment in full.
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