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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Inaction on the part of the first respondent in taking a decision - advance ruling u/s 97(1) of the Kerala State Goods and Services Tax Act - HC issued the directions.
Inaction on the part of the first respondent in taking a decision - advance ruling u/s 97(1) of the Kerala State Goods and Services Tax Act - HC issued the directions.
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