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...
Amended section 115UB deems non-business losses accumulated by an investment fund up to 31 March 2019 to be losses of unit holders holding units on that date. Unit holders may therefore carry forward their proportionate attributed share under the amended regime, rather than the fund retaining those losses. The disallowance of such carry-forward was set aside, subject to verification of the unit holder's factual entitlement and the losses attributed by the investment fund.
Amended section 115UB deems non-business losses accumulated by an investment fund up to 31 March 2019 to be losses of unit holders holding units on that date. Unit holders may therefore carry forward their proportionate attributed share under the amended regime, rather than the fund retaining those losses. The disallowance of such carry-forward was set aside, subject to verification of the unit holder's factual entitlement and the losses attributed by the investment fund.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
