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...
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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