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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.
Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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