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...
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Recall jurisdiction cannot be used to reopen a concluded order on its merits merely by alleging fraud in a notarised affidavit. Rules governing affidavit attestation, form and evidentiary acceptability distinguish rectifiable defects from deception that materially affects a decision; where the affidavit's contents are not denied, an attestation defect alone does not establish fraud. Third-party impleadment in a disciplinary appeal requires a direct legal right affected by the relief sought. A non-party cannot seek limited impleadment only in a stay application while remaining outside the main appeal, consistent with the principle of dominus litis.
Recall jurisdiction cannot be used to reopen a concluded order on its merits merely by alleging fraud in a notarised affidavit. Rules governing affidavit attestation, form and evidentiary acceptability distinguish rectifiable defects from deception that materially affects a decision; where the affidavit's contents are not denied, an attestation defect alone does not establish fraud. Third-party impleadment in a disciplinary appeal requires a direct legal right affected by the relief sought. A non-party cannot seek limited impleadment only in a stay application while remaining outside the main appeal, consistent with the principle of dominus litis.
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