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...
Import-policy amendments requiring an importer warehousing newsprint to be an RNI-registered Actual User operate prospectively from 3 June 2016 and do not invalidate earlier imports. Where the applicable customs exemption contains no RNI-registration or Actual User requirement, non-registration alone does not defeat the exemption. Customs should not independently characterise imports as contrary to the Foreign Trade Policy without a DGFT reference on the disputed policy interpretation. Confiscation and penalties for alleged clearance to dummy units require the Department first to establish foundational evidence of illicit import, improper clearance, or culpable conduct; rebutted procedural allegations and missing relied-upon material cannot support those consequences.
Import-policy amendments requiring an importer warehousing newsprint to be an RNI-registered Actual User operate prospectively from 3 June 2016 and do not invalidate earlier imports. Where the applicable customs exemption contains no RNI-registration or Actual User requirement, non-registration alone does not defeat the exemption. Customs should not independently characterise imports as contrary to the Foreign Trade Policy without a DGFT reference on the disputed policy interpretation. Confiscation and penalties for alleged clearance to dummy units require the Department first to establish foundational evidence of illicit import, improper clearance, or culpable conduct; rebutted procedural allegations and missing relied-upon material cannot support those consequences.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
