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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HC examined challenge to an appellate order setting aside a refund sanction relating to alleged zero-rated export of services under the IGST Act, 2017. HC held that the appellate authority had acted in violation of principles of natural justice, having failed to apply its mind or record adequate reasons, particularly regarding classification of services as exports and the applicability of s.13(3)-(13) IGST Act. Concluding that the impugned order was vitiated by non-application of mind, HC set it aside. The matter was remanded to the appellate authority for de novo consideration, with a direction to pass a reasoned order after granting due notice and hearing to the petitioner, who shall appear on 27.10.2025.
HC examined challenge to an appellate order setting aside a refund sanction relating to alleged zero-rated export of services under the IGST Act, 2017. HC held that the appellate authority had acted in violation of principles of natural justice, having failed to apply its mind or record adequate reasons, particularly regarding classification of services as exports and the applicability of s.13(3)-(13) IGST Act. Concluding that the impugned order was vitiated by non-application of mind, HC set it aside. The matter was remanded to the appellate authority for de novo consideration, with a direction to pass a reasoned order after granting due notice and hearing to the petitioner, who shall appear on 27.10.2025.
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