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...
GST rate reductions on cinema admission tickets must be passed to consumers through a commensurate price reduction, even where State rules prescribe maximum ticket prices. A maximum-price cap does not prevent lower pricing. Retaining cum-tax ticket prices while increasing the base price, without cogent justification and without challenging the computation, constituted failure to pass on the tax benefit; cost and market factors were immaterial. Where ticket recipients cannot be identified, the profiteered amount, with interest, is payable in equal shares to the Central and State Consumer Welfare Funds. An anti-profiteering penalty cannot be imposed retrospectively where the penalty provision entered into force after the investigated period.
GST rate reductions on cinema admission tickets must be passed to consumers through a commensurate price reduction, even where State rules prescribe maximum ticket prices. A maximum-price cap does not prevent lower pricing. Retaining cum-tax ticket prices while increasing the base price, without cogent justification and without challenging the computation, constituted failure to pass on the tax benefit; cost and market factors were immaterial. Where ticket recipients cannot be identified, the profiteered amount, with interest, is payable in equal shares to the Central and State Consumer Welfare Funds. An anti-profiteering penalty cannot be imposed retrospectively where the penalty provision entered into force after the investigated period.
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