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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FEMA adjudication requires the prescribed two-stage process: the adjudicating authority must form and communicate its opinion to hold an inquiry before granting a personal hearing. Non-compliance invalidated the adjudication order and consequential penalties, requiring fresh adjudication. Alleged FCCB contraventions also require consideration of the earlier RBI circular on eligibility to raise external commercial borrowings, alongside all relevant circulars and material. The matters were remitted for fresh determination after both sides received an opportunity.
FEMA adjudication requires the prescribed two-stage process: the adjudicating authority must form and communicate its opinion to hold an inquiry before granting a personal hearing. Non-compliance invalidated the adjudication order and consequential penalties, requiring fresh adjudication. Alleged FCCB contraventions also require consideration of the earlier RBI circular on eligibility to raise external commercial borrowings, alongside all relevant circulars and material. The matters were remitted for fresh determination after both sides received an opportunity.
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