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...
Section 50C applies to transfers of tenancy rights in land or buildings because a capital asset may be held through any legally recognised mode, not only ownership. Differences between leasehold and tenancy interests may affect the nature or value of the transferred interest but do not, by themselves, remove the transfer from the stamp-valuation framework. Where the stamp-value adopted exceeds the claimed fair market value, section 50C(2) provides for examination of the statutory conditions for a valuation reference. The Assessing Officer must consider the taxpayer's claim and, where conditions are met, obtain a Departmental Valuation Officer's valuation before determining the full value of consideration after providing an opportunity of hearing.
Section 50C applies to transfers of tenancy rights in land or buildings because a capital asset may be held through any legally recognised mode, not only ownership. Differences between leasehold and tenancy interests may affect the nature or value of the transferred interest but do not, by themselves, remove the transfer from the stamp-valuation framework. Where the stamp-value adopted exceeds the claimed fair market value, section 50C(2) provides for examination of the statutory conditions for a valuation reference. The Assessing Officer must consider the taxpayer's claim and, where conditions are met, obtain a Departmental Valuation Officer's valuation before determining the full value of consideration after providing an opportunity of hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
