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...
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Refund of education cess - area based exemption - appellant is entitle for the refund of education cess and secondary and higher education cess paid on clearances of the goods under Notification No. 56/2002-CE. - AT
Refund of education cess - area based exemption - appellant is entitle for the refund of education cess and secondary and higher education cess paid on clearances of the goods under Notification No. 56/2002-CE. - AT
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