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...
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...
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Waiver of pre deposit - appellants have already paid 10% duty while filing this appeal before this Tribunal. Therefore, it is treated that this 10% duty would be sufficient to hear their appeal on merits by the Commissioner (Appeals) - AT
Waiver of pre deposit - appellants have already paid 10% duty while filing this appeal before this Tribunal. Therefore, it is treated that this 10% duty would be sufficient to hear their appeal on merits by the Commissioner (Appeals) - AT
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