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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TDS credit on compulsory-acquisition compensation is tied to the assessment year in which the deduction is reflected in Form 26AS. Tax deducted during FY 2022-23 and reflected for AY 2023-24 cannot be claimed for AY 2024-25. The procedure under section 155(20), Rule 134 and Form 71 does not alter that factual alignment; any entitlement for AY 2023-24 remains subject to independent adjudication.
TDS credit on compulsory-acquisition compensation is tied to the assessment year in which the deduction is reflected in Form 26AS. Tax deducted during FY 2022-23 and reflected for AY 2023-24 cannot be claimed for AY 2024-25. The procedure under section 155(20), Rule 134 and Form 71 does not alter that factual alignment; any entitlement for AY 2023-24 remains subject to independent adjudication.
Note: It is a system-generated summary and is for quick reference only.
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