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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Wrong-head GST remittances, where a taxpayer timely pays the full aggregate liability but selects an incorrect tax head, are distinct from a later correction of a supply's inter-State or intra-State character. Sections 19 of the IGST Act and 77 of the CGST Act, with Rule 89(1A), address classification errors and the related refund framework, not a pure allocation error. An identifiable wrong-head payment may be appropriated against the correct CGST and SGST liabilities rather than requiring duplicate payment followed by refund. Where funds remain in the electronic cash ledger, Section 49(10) and Rule 87(13) permit inter-head transfer through FORM GST PMT-09; refund may be procedurally necessary if transfer is unavailable.
Wrong-head GST remittances, where a taxpayer timely pays the full aggregate liability but selects an incorrect tax head, are distinct from a later correction of a supply's inter-State or intra-State character. Sections 19 of the IGST Act and 77 of the CGST Act, with Rule 89(1A), address classification errors and the related refund framework, not a pure allocation error. An identifiable wrong-head payment may be appropriated against the correct CGST and SGST liabilities rather than requiring duplicate payment followed by refund. Where funds remain in the electronic cash ledger, Section 49(10) and Rule 87(13) permit inter-head transfer through FORM GST PMT-09; refund may be procedurally necessary if transfer is unavailable.
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