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...
DGFT regularisation of EPCG imports after payment of duty and interest rendered confiscation of the imported goods and penalty for non-fulfilment of export obligation unsustainable. The Tribunal allowed relief from confiscation and penalty while leaving the unchallenged duty and interest liability intact. Duty foregone on capital goods imported under an EPCG licence must be computed using the assessable value declared in the Bill of Entry, rather than the value stated in the licence.
DGFT regularisation of EPCG imports after payment of duty and interest rendered confiscation of the imported goods and penalty for non-fulfilment of export obligation unsustainable. The Tribunal allowed relief from confiscation and penalty while leaving the unchallenged duty and interest liability intact. Duty foregone on capital goods imported under an EPCG licence must be computed using the assessable value declared in the Bill of Entry, rather than the value stated in the licence.
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