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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Unutilised capital gains claiming section 54 exemption must be deposited in the Capital Gains Account Scheme by the section 139(1) return-filing date where they have not been used for eligible residential investment. Exemption remains available only for gains utilised by that date; later payments do not qualify. This limitation applies even where two adjacent residential units are treated as one residential unit. The exemption was restricted to timely utilised gains, and interest under sections 234B and 234D was sustained as consequential and mandatory.
Unutilised capital gains claiming section 54 exemption must be deposited in the Capital Gains Account Scheme by the section 139(1) return-filing date where they have not been used for eligible residential investment. Exemption remains available only for gains utilised by that date; later payments do not qualify. This limitation applies even where two adjacent residential units are treated as one residential unit. The exemption was restricted to timely utilised gains, and interest under sections 234B and 234D was sustained as consequential and mandatory.
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