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...
Reliance on a previously quashed departmental circular could not sustain rejection of an inverted-duty refund claim for cotton-yarn clearances. High Court quashed the appellate order because it rested on that circular and required fresh examination of the inputs procured and their use in manufacturing and clearing cotton yarn before refund eligibility could be determined. The refund claims were remitted for fresh examination, with refund to be granted if eligibility is established.
Reliance on a previously quashed departmental circular could not sustain rejection of an inverted-duty refund claim for cotton-yarn clearances. High Court quashed the appellate order because it rested on that circular and required fresh examination of the inputs procured and their use in manufacturing and clearing cotton yarn before refund eligibility could be determined. The refund claims were remitted for fresh examination, with refund to be granted if eligibility is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
