Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmarking.

Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmarking. https://www.taxtmi.com/highlights?id=104899 Prior-period expenditure is allowable where the liability, including its particulars and quantum, became known and ascertainable only in the relevant year; invoices may be recorded on crystallisation notwithstanding that the underlying expenditure relates to an earlier period. Transfer-pricing analysis must separately benchmark functionally distinct consulting and captive back-office divisions where their functions, methods and economic profiles differ. Entity-level aggregation is unsustainable in those circumstances, supporting deletion of the related adjustment. en-us Tue, 13 Oct 2026 10:10:46 +0530 Tue, 13 Oct 2026 10:10:46 +0530 TaxTMI RSS Generator Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmarking. https://www.taxtmi.com/highlights?id=104899 Prior-period expenditure is allowable where the liability, including its particulars and quantum, became known and ascertainable only in the relevant year; invoices may be recorded on crystallisation notwithstanding that the underlying expenditure relates to an earlier period. Transfer-pricing analysis must separately benchmark functionally distinct consulting and captive back-office divisions where their functions, methods and economic profiles differ. Entity-level aggregation is unsustainable in those circumstances, supporting deletion of the related adjustment. Highlights Income Tax Tue, 13 Oct 2026 10:10:46 +0530 https://www.taxtmi.com/highlights?id=104899