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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Anti-dumping duty on castings for wind-operated electricity generators extends to castings incorporated in a sub-assembly, equipment or component, but not to complete equipment or components themselves. The unchallenged Tribunal interpretation of that limitation had attained finality and bound Customs authorities, and identical imports had been assessed consistently. Consequently, final assessment imposing anti-dumping duty on imported wind-turbine gear boxes lacked statutory authority; the self-assessment was to be accepted, with release of the bond and bank guarantees.
Anti-dumping duty on castings for wind-operated electricity generators extends to castings incorporated in a sub-assembly, equipment or component, but not to complete equipment or components themselves. The unchallenged Tribunal interpretation of that limitation had attained finality and bound Customs authorities, and identical imports had been assessed consistently. Consequently, final assessment imposing anti-dumping duty on imported wind-turbine gear boxes lacked statutory authority; the self-assessment was to be accepted, with release of the bond and bank guarantees.
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