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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Non-supply of relied-upon documents with the show-cause notice and refusal to permit requested cross-examination were held to breach the principles of natural justice and the right to a fair hearing; the impugned order was quashed and the matter remanded for a fresh inquiry from the stage of issuance of the show-cause notice. The respondents are directed to supply all relied-upon documents with a list of RUDs, permit cross-examination where requested, and complete the inquiry in accordance with law within three months.
Non-supply of relied-upon documents with the show-cause notice and refusal to permit requested cross-examination were held to breach the principles of natural justice and the right to a fair hearing; the impugned order was quashed and the matter remanded for a fresh inquiry from the stage of issuance of the show-cause notice. The respondents are directed to supply all relied-upon documents with a list of RUDs, permit cross-examination where requested, and complete the inquiry in accordance with law within three months.
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