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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GST audit commencement under the Explanation to Section 65(4) is reckoned from the later of record furnishing and on-site institution at the registered person's business premises. An audit following prior production of records therefore remains within time if completed within the statutory period measured from on-site commencement. Rule 101(4) requires the registered person to receive an opportunity to object to discrepancies and have those objections considered before audit findings are finalised. Audit observations seeking a response are not final findings and cannot properly support a show cause notice before that procedure is completed. Objections must be received and considered before fresh finalisation of the audit.
GST audit commencement under the Explanation to Section 65(4) is reckoned from the later of record furnishing and on-site institution at the registered person's business premises. An audit following prior production of records therefore remains within time if completed within the statutory period measured from on-site commencement. Rule 101(4) requires the registered person to receive an opportunity to object to discrepancies and have those objections considered before audit findings are finalised. Audit observations seeking a response are not final findings and cannot properly support a show cause notice before that procedure is completed. Objections must be received and considered before fresh finalisation of the audit.
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TaxTMI 
TaxTMI 
