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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Provisional release of seized Ketamine Hydrochloride for export was warranted where a fresh export authorisation covered the same goods after the original authorisation had expired following replacement of the shipment batch. The High Court treated the delay in obtaining the fresh authorisation as technical because the goods remained unexported and the licensing authority had accepted the new authorisation as valid. Customs could not deny its effect merely because the licensing authority had not expressly authorised release of the seized goods. Union departments must maintain consistent positions on the same export transaction. The rejection of provisional release was quashed, subject to a Customs deposit, while adjudication and criminal proceedings remained unaffected.
Provisional release of seized Ketamine Hydrochloride for export was warranted where a fresh export authorisation covered the same goods after the original authorisation had expired following replacement of the shipment batch. The High Court treated the delay in obtaining the fresh authorisation as technical because the goods remained unexported and the licensing authority had accepted the new authorisation as valid. Customs could not deny its effect merely because the licensing authority had not expressly authorised release of the seized goods. Union departments must maintain consistent positions on the same export transaction. The rejection of provisional release was quashed, subject to a Customs deposit, while adjudication and criminal proceedings remained unaffected.
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