Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly.
Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly.
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