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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Advance-ruling applications may cover ongoing import activities after removal of the requirement that the activity be merely proposed, provided the question is neither pending nor settled by a competent forum; rulings operate prospectively. Battery-specific die-cut insulating tape, imported in pre-cut profiles for direct incorporation into lithium-ion battery packs, is classified as other parts of electric accumulators under CTI 8507 90 90. Continuous self-adhesive plastic tape in rolls remains classified at import as plastic adhesive tape under CTI 3919 10 00, notwithstanding post-import cutting. Both products may receive concessional basic customs duty for battery-pack manufacture, subject to specified end use, prescribed conditions, and compliance with the IGCR Rules, 2022.
Advance-ruling applications may cover ongoing import activities after removal of the requirement that the activity be merely proposed, provided the question is neither pending nor settled by a competent forum; rulings operate prospectively. Battery-specific die-cut insulating tape, imported in pre-cut profiles for direct incorporation into lithium-ion battery packs, is classified as other parts of electric accumulators under CTI 8507 90 90. Continuous self-adhesive plastic tape in rolls remains classified at import as plastic adhesive tape under CTI 3919 10 00, notwithstanding post-import cutting. Both products may receive concessional basic customs duty for battery-pack manufacture, subject to specified end use, prescribed conditions, and compliance with the IGCR Rules, 2022.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
