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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Global ranking support services involving institutional support, commercial facilitation, coordination, benchmarking, data organisation and reporting are characterised by their actual nature, not contractual labels, skill level or tax deduction under section 194J. Section 44ADA is confined to professions listed in section 44AA(1); advisory or consultancy descriptions do not alone make receipts professional. Where the activity is not a specified or notified profession, qualifying technical consultancy, commission or brokerage, or agency business, it is treated as business activity for section 44AD rather than professional receipts under section 44ADA. A 70% profit estimate lacks a statutory basis where section 44ADA does not apply. Tax deducted at source credit requires verification against Form 26AS before allowance.
Global ranking support services involving institutional support, commercial facilitation, coordination, benchmarking, data organisation and reporting are characterised by their actual nature, not contractual labels, skill level or tax deduction under section 194J. Section 44ADA is confined to professions listed in section 44AA(1); advisory or consultancy descriptions do not alone make receipts professional. Where the activity is not a specified or notified profession, qualifying technical consultancy, commission or brokerage, or agency business, it is treated as business activity for section 44AD rather than professional receipts under section 44ADA. A 70% profit estimate lacks a statutory basis where section 44ADA does not apply. Tax deducted at source credit requires verification against Form 26AS before allowance.
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