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...
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Liquid crystal display panels imported for assembly into automotive instrument clusters are classified as liquid crystal devices under CTI 9013 8010, rather than motor-vehicle parts under CTI 87089900 or 87141090. The specific-heading rule and Chapter 90 Note 2(a) preserve Chapter 90 classification where goods are covered by its heading, despite their sole or principal automotive use. Consequently, the declared classification stands, and differential duty, interest and penalties under vehicle-parts classifications are unsustainable.
Liquid crystal display panels imported for assembly into automotive instrument clusters are classified as liquid crystal devices under CTI 9013 8010, rather than motor-vehicle parts under CTI 87089900 or 87141090. The specific-heading rule and Chapter 90 Note 2(a) preserve Chapter 90 classification where goods are covered by its heading, despite their sole or principal automotive use. Consequently, the declared classification stands, and differential duty, interest and penalties under vehicle-parts classifications are unsustainable.
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