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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Section 75(7) bars confirmation of a demand exceeding the scope of the show cause notice. Where a notice does not propose a penalty, an adjudicating authority cannot impose one in the final order; such confirmation exceeds jurisdiction. An adjudication order imposing an unnotified penalty was therefore set aside, and the matter was remitted for fresh adjudication after giving the petitioner an opportunity of hearing.
Section 75(7) bars confirmation of a demand exceeding the scope of the show cause notice. Where a notice does not propose a penalty, an adjudicating authority cannot impose one in the final order; such confirmation exceeds jurisdiction. An adjudication order imposing an unnotified penalty was therefore set aside, and the matter was remitted for fresh adjudication after giving the petitioner an opportunity of hearing.
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TaxTMI 
TaxTMI 
