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...
Refund of IGST - tax paid on Ocean Freight under the reverse charge mechanism - his Court held that the levy of the IGST under the RCM on the Ocean Freight for the service provided by a person located in a non-taxable territory by way of transportation of goods through vessel from a place outside India to customs frontier of India is unconstitutional. - Refund to be allowed - Period of limitation u//s Section 54 of the CGST Act is not applicable - general provisions provided under the Limitation Act is applicable to claim refund of such duty - HC
Refund of IGST - tax paid on Ocean Freight under the reverse charge mechanism - his Court held that the levy of the IGST under the RCM on the Ocean Freight for the service provided by a person located in a non-taxable territory by way of transportation of goods through vessel from a place outside India to customs frontier of India is unconstitutional. - Refund to be allowed - Period of limitation u//s Section 54 of the CGST Act is not applicable - general provisions provided under the Limitation Act is applicable to claim refund of such duty - HC
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