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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Section 112(a) penalty for an importer's alleged misclassification of removable or exchangeable disc drives was treated as lacking a legal basis where the goods were unavailable at adjudication and no actual confiscation or redemption fine was imposed. The related duty demand and penalties imposed on the importer under the same adjudication order had also been set aside. On these grounds, the Director's penalty for the alleged misclassification was unsustainable and was set aside.
Section 112(a) penalty for an importer's alleged misclassification of removable or exchangeable disc drives was treated as lacking a legal basis where the goods were unavailable at adjudication and no actual confiscation or redemption fine was imposed. The related duty demand and penalties imposed on the importer under the same adjudication order had also been set aside. On these grounds, the Director's penalty for the alleged misclassification was unsustainable and was set aside.
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