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...
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The court found the petition maintainable despite the time limitation, as the petitioner failed to notice the show cause notice (SCN) posted on the GST common portal. Partial relief was granted by quashing the impugned order and remitting the case back to the respondent for fresh orders, subject to the petitioner depositing 10% of the disputed tax from its Electronic Cash Register. The quashed order shall be treated as an addendum to the preceding show cause notice.
The court found the petition maintainable despite the time limitation, as the petitioner failed to notice the show cause notice (SCN) posted on the GST common portal. Partial relief was granted by quashing the impugned order and remitting the case back to the respondent for fresh orders, subject to the petitioner depositing 10% of the disputed tax from its Electronic Cash Register. The quashed order shall be treated as an addendum to the preceding show cause notice.
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