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...
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Section 41(1) applies only where the taxpayer obtains a benefit during the relevant year through remission or cessation of a trading liability previously allowed as a deduction. Age of a liability, absent creditor confirmation, lack of recovery action or expiry of limitation does not establish cessation where the liability remains acknowledged in the accounts; subsequent payment may confirm that it continued at year-end. Advance-tax interest for a company remains mandatory but must be calculated on tax due on returned income, subject to statutory adjustments and credit for tax deducted at source and advance tax, rather than on subsequently assessed income.
Section 41(1) applies only where the taxpayer obtains a benefit during the relevant year through remission or cessation of a trading liability previously allowed as a deduction. Age of a liability, absent creditor confirmation, lack of recovery action or expiry of limitation does not establish cessation where the liability remains acknowledged in the accounts; subsequent payment may confirm that it continued at year-end. Advance-tax interest for a company remains mandatory but must be calculated on tax due on returned income, subject to statutory adjustments and credit for tax deducted at source and advance tax, rather than on subsequently assessed income.
Note: It is a system-generated summary and is for quick reference only.