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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A subsisting interim direction prohibiting tax deduction from leave travel concession reimbursements prevents the employer from being treated as an assessee in default for the period covered by that restraint. This protection concerns the employer's withholding duty and does not make foreign-leg or circuitous travel eligible for the leave travel concession exemption, which remains confined to actual qualifying travel within India under the statutory conditions and prescribed limits. Employee tax liability may remain payable directly where the exemption ultimately fails. For periods without judicial protection, employers must examine travel eligibility and may avoid payer-default consequences only by establishing employee return filing, income inclusion and tax payment through the prescribed certification process.
A subsisting interim direction prohibiting tax deduction from leave travel concession reimbursements prevents the employer from being treated as an assessee in default for the period covered by that restraint. This protection concerns the employer's withholding duty and does not make foreign-leg or circuitous travel eligible for the leave travel concession exemption, which remains confined to actual qualifying travel within India under the statutory conditions and prescribed limits. Employee tax liability may remain payable directly where the exemption ultimately fails. For periods without judicial protection, employers must examine travel eligibility and may avoid payer-default consequences only by establishing employee return filing, income inclusion and tax payment through the prescribed certification process.
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