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...
Jewellery claimed as streedhan, customary family holdings and marriage gifts cannot be treated as unexplained solely through an ad hoc addition where family ownership is supported by affidavits and photographs, the family's status and past income are relevant, and no Revenue valuation exists. Jewellery accumulated in earlier years need not correlate with income declared for the relevant year, and married daughters may lawfully keep jewellery at their parental home. Cash found in a search is not unexplained where bank records establish sufficient withdrawals by the individual and family members. On these grounds, additions for jewellery and cash were deleted.
Jewellery claimed as streedhan, customary family holdings and marriage gifts cannot be treated as unexplained solely through an ad hoc addition where family ownership is supported by affidavits and photographs, the family's status and past income are relevant, and no Revenue valuation exists. Jewellery accumulated in earlier years need not correlate with income declared for the relevant year, and married daughters may lawfully keep jewellery at their parental home. Cash found in a search is not unexplained where bank records establish sufficient withdrawals by the individual and family members. On these grounds, additions for jewellery and cash were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
