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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Disallowance of a cost of improvement claimed in calculating short-term capital gains, merely because contractor-level documentation is incomplete, does not by itself establish misrepresentation or suppression. Where the improvement work is undisputed and the expenditure has been disclosed in the return and supporting particulars, the income cannot be treated as underreported as a consequence of misreporting. Contractor-level evidence may be unjustified for incidental capital expenditure outside the taxpayer's regular business. The penalty for underreported income under section 270A was quashed.
Disallowance of a cost of improvement claimed in calculating short-term capital gains, merely because contractor-level documentation is incomplete, does not by itself establish misrepresentation or suppression. Where the improvement work is undisputed and the expenditure has been disclosed in the return and supporting particulars, the income cannot be treated as underreported as a consequence of misreporting. Contractor-level evidence may be unjustified for incidental capital expenditure outside the taxpayer's regular business. The penalty for underreported income under section 270A was quashed.
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