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...
Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.
Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
