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...
Bill-to/Ship-to transactions permit an intermediate purchaser to instruct the original supplier to dispatch goods directly to the ultimate recipient, provided the supplies are genuine, documented and properly accounted for. Rule 138(2) allows the consignor or consignee causing movement to generate the e-way bill. Where e-invoices and e-way bills are generated before interception by the party arranging transport, the supplier's separate non-generation does not justify detention of goods. Compliance with these requirements makes detention and penalty for e-way bill non-compliance unsustainable.
Bill-to/Ship-to transactions permit an intermediate purchaser to instruct the original supplier to dispatch goods directly to the ultimate recipient, provided the supplies are genuine, documented and properly accounted for. Rule 138(2) allows the consignor or consignee causing movement to generate the e-way bill. Where e-invoices and e-way bills are generated before interception by the party arranging transport, the supplier's separate non-generation does not justify detention of goods. Compliance with these requirements makes detention and penalty for e-way bill non-compliance unsustainable.
Note: It is a system-generated summary and is for quick reference only.