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...
Section 28 permits recovery of unpaid or short-paid anti-dumping duty through a demand notice without first challenging the importer's self-assessment. This recovery mechanism is distinct from refund proceedings, where an unmodified self-assessment may restrict relief. Anti-dumping duty imposed under the Customs Tariff Act is treated as customs duty for calculating IGST on imported goods; IGST therefore applies to the aggregate value including such duty. The maximum penalty for non-payment is governed by the statutory ceiling applicable on the date of import, and a subsequently enhanced ceiling cannot apply retrospectively.
Section 28 permits recovery of unpaid or short-paid anti-dumping duty through a demand notice without first challenging the importer's self-assessment. This recovery mechanism is distinct from refund proceedings, where an unmodified self-assessment may restrict relief. Anti-dumping duty imposed under the Customs Tariff Act is treated as customs duty for calculating IGST on imported goods; IGST therefore applies to the aggregate value including such duty. The maximum penalty for non-payment is governed by the statutory ceiling applicable on the date of import, and a subsequently enhanced ceiling cannot apply retrospectively.
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