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...
Section 263 revision of a limited-scrutiny assessment requires conversion to complete scrutiny under applicable instructions before wider issues may be revised. Revision also requires the Principal Commissioner independently to call for and examine the assessment record and form the statutory opinion; an Assessing Officer's proposal responding to an audit objection does not itself meet that jurisdictional condition. Interest awarded on enhanced compensation under section 28 of the Land Acquisition Act is an accretion to land value and forms part of enhanced compensation, unlike interest for delayed payment under section 34. Later provisions taxing interest on receipt do not alter that character, and a debatable issue cannot render an assessment erroneous and prejudicial.
Section 263 revision of a limited-scrutiny assessment requires conversion to complete scrutiny under applicable instructions before wider issues may be revised. Revision also requires the Principal Commissioner independently to call for and examine the assessment record and form the statutory opinion; an Assessing Officer's proposal responding to an audit objection does not itself meet that jurisdictional condition. Interest awarded on enhanced compensation under section 28 of the Land Acquisition Act is an accretion to land value and forms part of enhanced compensation, unlike interest for delayed payment under section 34. Later provisions taxing interest on receipt do not alter that character, and a debatable issue cannot render an assessment erroneous and prejudicial.
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TaxTMI 
TaxTMI 
of 4915 
