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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...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Excess managerial remuneration, previously taxed but later finally determined and actually recovered by the employer, may be adjusted against salary income in the year of recovery. The adjustment operates under section 15 as recognition of remuneration the employee was not entitled to retain, rather than as a deduction of expenditure under section 16. Annuality of assessment does not prevent recognition of the distinct subsequent recovery where its genuineness and repayment are undisputed. The original year's salary assessment and tax deduction remain undisturbed.
Excess managerial remuneration, previously taxed but later finally determined and actually recovered by the employer, may be adjusted against salary income in the year of recovery. The adjustment operates under section 15 as recognition of remuneration the employee was not entitled to retain, rather than as a deduction of expenditure under section 16. Annuality of assessment does not prevent recognition of the distinct subsequent recovery where its genuineness and repayment are undisputed. The original year's salary assessment and tax deduction remain undisturbed.
Note: It is a system-generated summary and is for quick reference only.