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...
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Joint development arrangements may involve non-monetary consideration where land or development rights are exchanged for flats, but taxability depends on contractual rights and obligations. Valuation follows only after identifying a taxable service, and comparable-flat values require genuine comparability and verification against duplicate taxation. Builder-developer construction before 1 July 2010 may qualify as self-service if applicable factual conditions are met; composite works contracts must be distinguished from pure construction services by contractual transfer of property in goods. An incorrect statutory citation does not alone invalidate an otherwise sustainable notice. Reverse-charge liability requires proof of qualifying GTA, security, manpower-supply or legal services. Extended limitation requires deliberate suppression with intent to evade tax.
Joint development arrangements may involve non-monetary consideration where land or development rights are exchanged for flats, but taxability depends on contractual rights and obligations. Valuation follows only after identifying a taxable service, and comparable-flat values require genuine comparability and verification against duplicate taxation. Builder-developer construction before 1 July 2010 may qualify as self-service if applicable factual conditions are met; composite works contracts must be distinguished from pure construction services by contractual transfer of property in goods. An incorrect statutory citation does not alone invalidate an otherwise sustainable notice. Reverse-charge liability requires proof of qualifying GTA, security, manpower-supply or legal services. Extended limitation requires deliberate suppression with intent to evade tax.
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