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...
Calculation of duty at the time of finalization of final assessment - import of HSD and SKO - to be paid on the basis of invoice value and the quantity indicated on the bills of lading or the quantity received by the importer/ appellants in their warehouse/ shore tanks? - actual oil quantity physically received into the shore tank should be taken as the basis for payment of duty at the time of ex-bond bills of entry. - AT
Calculation of duty at the time of finalization of final assessment - import of HSD and SKO - to be paid on the basis of invoice value and the quantity indicated on the bills of lading or the quantity received by the importer/ appellants in their warehouse/ shore tanks? - actual oil quantity physically received into the shore tank should be taken as the basis for payment of duty at the time of ex-bond bills of entry. - AT
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