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...
Enhancement in declared value of import - Appellant has declared the same description what is given in the invoice/customs documents not only in the present bill of entry but in the other imports of the same appellant - There is no wilful misstatement on the part of the appellant or any evidence indicating that some extra amount has been repatriated to the supplier for the present consignment - Demand set aside - AT
Enhancement in declared value of import - Appellant has declared the same description what is given in the invoice/customs documents not only in the present bill of entry but in the other imports of the same appellant - There is no wilful misstatement on the part of the appellant or any evidence indicating that some extra amount has been repatriated to the supplier for the present consignment - Demand set aside - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4927 
