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...
Capital goods intended for use in a warehouse authorised to undertake manufacture or other operations may remain warehoused until clearance under the amended customs framework. Interest on warehoused goods is confined to residuary goods and does not apply to capital goods falling within the specified category. Intended use is determined when the goods are imported and warehoused; actual subsequent use is not required. Solar modules intended for a solar power project retained their character as capital goods despite becoming surplus because of later design and layout changes. A circular concerning clearance for non-manufacturing purposes cannot impose interest where the statute does not provide for it.
Capital goods intended for use in a warehouse authorised to undertake manufacture or other operations may remain warehoused until clearance under the amended customs framework. Interest on warehoused goods is confined to residuary goods and does not apply to capital goods falling within the specified category. Intended use is determined when the goods are imported and warehoused; actual subsequent use is not required. Solar modules intended for a solar power project retained their character as capital goods despite becoming surplus because of later design and layout changes. A circular concerning clearance for non-manufacturing purposes cannot impose interest where the statute does not provide for it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
