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...
Tariff rate quota benefits applied to qualifying imports of crude soybean oil, making refund of excess customs duty admissible. The position followed prior rulings concerning the same product and import period, and Revenue did not contest it. The refusal of refund was set aside, and the refund claim was required to be processed in accordance with law within three months.
Tariff rate quota benefits applied to qualifying imports of crude soybean oil, making refund of excess customs duty admissible. The position followed prior rulings concerning the same product and import period, and Revenue did not contest it. The refusal of refund was set aside, and the refund claim was required to be processed in accordance with law within three months.
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