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...
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The High Court quashed the impugned summary order passed without issuing Form DRC-01 show cause notice to the petitioner, violating principles of natural justice. The matter was remanded to the respondent authorities for de novo adjudication after providing an opportunity of hearing to the petitioner. Fresh order to be passed within 12 weeks in accordance with law. The petition was disposed of by way of remand.
The High Court quashed the impugned summary order passed without issuing Form DRC-01 show cause notice to the petitioner, violating principles of natural justice. The matter was remanded to the respondent authorities for de novo adjudication after providing an opportunity of hearing to the petitioner. Fresh order to be passed within 12 weeks in accordance with law. The petition was disposed of by way of remand.
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TaxTMI 
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