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...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Under Valuation of imported goods - in the absence of corroboration and cogent evidence, the Department’s case is based upon assumption and presumption, that the goods in normal packing were having the same value as the branded and vacuumed packed goods - Demand set aside.
Under Valuation of imported goods - in the absence of corroboration and cogent evidence, the Department’s case is based upon assumption and presumption, that the goods in normal packing were having the same value as the branded and vacuumed packed goods - Demand set aside.
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