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...
Input tax credit remains conditional on actual payment of the tax charged by the supplier to the Government. The statutory conditions for credit operate conjointly; a recipient who avails credit without ensuring that the supplier paid the corresponding tax cannot retain it, and the credit is recoverable according to law. Supplier insolvency and an approved insolvency resolution plan do not waive or displace this statutory tax-payment condition. The writ petition challenging recovery of the credit was dismissed.
Input tax credit remains conditional on actual payment of the tax charged by the supplier to the Government. The statutory conditions for credit operate conjointly; a recipient who avails credit without ensuring that the supplier paid the corresponding tax cannot retain it, and the credit is recoverable according to law. Supplier insolvency and an approved insolvency resolution plan do not waive or displace this statutory tax-payment condition. The writ petition challenging recovery of the credit was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
