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...
Overseas Education Advisory services - promotion of courses of foreign universities among prospective students - The place of supply is the territory of India - As the condition under section 2(6)(iii) of the IGST Act is not satisfied - The activity does not qualify as “Export of Services” - AAR
Overseas Education Advisory services - promotion of courses of foreign universities among prospective students - The place of supply is the territory of India - As the condition under section 2(6)(iii) of the IGST Act is not satisfied - The activity does not qualify as “Export of Services” - AAR
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