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...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.
Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.
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