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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Late-presentation charges for a Bill of Entry arise only where the proper officer, after assessing the reasons for delay, is satisfied that no sufficient cause exists. Regulation 4(3) prescribes the charging framework and permits waiver where the reasons are satisfactory; automated calculation cannot replace this statutory assessment. For supplementary Bills of Entry covering excess cargo subsequently identified as part of a timely declared consignment, waiver depends on causation, importer fault, bona fide and prompt corrective action, amendment requests, and willingness to discharge undisputed duty. A legally sustainable refusal or grant of waiver requires a reasoned evaluation of evidence rather than mechanical reliance on delayed filing.
Late-presentation charges for a Bill of Entry arise only where the proper officer, after assessing the reasons for delay, is satisfied that no sufficient cause exists. Regulation 4(3) prescribes the charging framework and permits waiver where the reasons are satisfactory; automated calculation cannot replace this statutory assessment. For supplementary Bills of Entry covering excess cargo subsequently identified as part of a timely declared consignment, waiver depends on causation, importer fault, bona fide and prompt corrective action, amendment requests, and willingness to discharge undisputed duty. A legally sustainable refusal or grant of waiver requires a reasoned evaluation of evidence rather than mechanical reliance on delayed filing.
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