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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MEIS benefits under a beneficial export-incentive scheme cannot be refused solely because 'Y' was selected only for the first item in each electronic shipping bill, where genuine notified exports were made and the exporter otherwise declared an intention to claim rewards. The omission was treated as an inadvertent procedural lapse rather than a bar to entitlement. Absence of physical examination did not defeat the claim, since the initial 'Y' selection did not affect Customs' ability to examine the goods. Processing of the MEIS claim was therefore permitted.
MEIS benefits under a beneficial export-incentive scheme cannot be refused solely because 'Y' was selected only for the first item in each electronic shipping bill, where genuine notified exports were made and the exporter otherwise declared an intention to claim rewards. The omission was treated as an inadvertent procedural lapse rather than a bar to entitlement. Absence of physical examination did not defeat the claim, since the initial 'Y' selection did not affect Customs' ability to examine the goods. Processing of the MEIS claim was therefore permitted.
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