Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
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