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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Pre-CIRP statutory income-tax claims not forming part of an approved resolution plan are treated as extinguished, preventing continuation of proceedings concerning those claims. This principle applies where a corporate debtor's successor entered the corporate insolvency resolution process, an approved resolution plan was not implemented, and liquidation followed. No material established admission of the Department's claims for the relevant assessment years in the resolution or liquidation proceedings; the connected Departmental appeals, assessee appeal, and cross-objection therefore did not survive.
Pre-CIRP statutory income-tax claims not forming part of an approved resolution plan are treated as extinguished, preventing continuation of proceedings concerning those claims. This principle applies where a corporate debtor's successor entered the corporate insolvency resolution process, an approved resolution plan was not implemented, and liquidation followed. No material established admission of the Department's claims for the relevant assessment years in the resolution or liquidation proceedings; the connected Departmental appeals, assessee appeal, and cross-objection therefore did not survive.
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