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...
Defence end-use customs exemption applies on a functional, end-use basis to missile-warning-system components with a demonstrable nexus to military aircraft; tariff classification is not determinative. The specified imaging lens, sensor front-end and coupling unit qualify in principle as aircraft sub-assemblies and, alternatively, accessories because they are engineered exclusively for a missile-warning system fitted in military helicopters; specified weapon exclusions do not apply. Private defence suppliers may use the exemption, but Condition 17 requires a prescribed Ministry of Defence certificate issued by an officer not below Joint Secretary rank at import. An Indian Air Force end-use certificate alone is insufficient. Each consignment remains subject to mandatory certification and Customs verification.
Defence end-use customs exemption applies on a functional, end-use basis to missile-warning-system components with a demonstrable nexus to military aircraft; tariff classification is not determinative. The specified imaging lens, sensor front-end and coupling unit qualify in principle as aircraft sub-assemblies and, alternatively, accessories because they are engineered exclusively for a missile-warning system fitted in military helicopters; specified weapon exclusions do not apply. Private defence suppliers may use the exemption, but Condition 17 requires a prescribed Ministry of Defence certificate issued by an officer not below Joint Secretary rank at import. An Indian Air Force end-use certificate alone is insufficient. Each consignment remains subject to mandatory certification and Customs verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
