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...
Request for modification of Advance Ruling - Classification of Echo Dot with clock - Benefit of exemption notifications on their import. - The previous ruling classified Echo Dot (5th Generation) and Echo Dot (5th Generation) with clock under sub-heading 8518 22 10 of the Customs Tariff Act, 1975. - It also determined that exemptions were not applicable to these products. - The authority held that, the ruling on the classification of Echo Dot (5th Generation) and Echo Dot (5th Generation) with clock was not made under any mistake. - The modification petition dismissed.
Request for modification of Advance Ruling - Classification of Echo Dot with clock - Benefit of exemption notifications on their import. - The previous ruling classified Echo Dot (5th Generation) and Echo Dot (5th Generation) with clock under sub-heading 8518 22 10 of the Customs Tariff Act, 1975. - It also determined that exemptions were not applicable to these products. - The authority held that, the ruling on the classification of Echo Dot (5th Generation) and Echo Dot (5th Generation) with clock was not made under any mistake. - The modification petition dismissed.
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