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...
For non-notified goods such as black pepper and socks, the Customs Act places the burden on Revenue to prove their smuggled character before confiscation can be sustained. Failure to discharge that burden means the goods are not liable to confiscation, and penalties imposed solely as a consequence of confiscation cannot stand. The confiscation order and consequential penalties were set aside, with consequential relief.
For non-notified goods such as black pepper and socks, the Customs Act places the burden on Revenue to prove their smuggled character before confiscation can be sustained. Failure to discharge that burden means the goods are not liable to confiscation, and penalties imposed solely as a consequence of confiscation cannot stand. The confiscation order and consequential penalties were set aside, with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
