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...
Customs duty exemptions apply according to the notification in force when Bills of Entry are filed. Carbon Less Paper Black Image classifiable under CTH 48099000 was not covered after Notification No. 46/2011-Cus. ceased to operate, while Notification No. 127/2011-Cus. extended the effective rate only to CTH 470790. Notification No. 35/2013-Cus. took effect prospectively upon Gazette publication and did not restore concessional duty for earlier imports; the exemption claim therefore failed. Claiming exemption under a superseded notification supported invocation of the extended limitation period for duty recovery, as importers are presumed to know applicable amendments.
Customs duty exemptions apply according to the notification in force when Bills of Entry are filed. Carbon Less Paper Black Image classifiable under CTH 48099000 was not covered after Notification No. 46/2011-Cus. ceased to operate, while Notification No. 127/2011-Cus. extended the effective rate only to CTH 470790. Notification No. 35/2013-Cus. took effect prospectively upon Gazette publication and did not restore concessional duty for earlier imports; the exemption claim therefore failed. Claiming exemption under a superseded notification supported invocation of the extended limitation period for duty recovery, as importers are presumed to know applicable amendments.
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