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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Customs exemption notification amendments operate prospectively unless they expressly provide for retrospective effect. An amendment commencing after the relevant Bills of Lading cannot govern imports of second-hand highly specialised equipment covered by those earlier Bills or justify refusal to consider provisional release. The request for provisional release must instead be considered under the law applicable to those imports; upon satisfaction of imposed conditions, the goods are to be released provisionally, without prejudice to independent adjudication proceedings.
Customs exemption notification amendments operate prospectively unless they expressly provide for retrospective effect. An amendment commencing after the relevant Bills of Lading cannot govern imports of second-hand highly specialised equipment covered by those earlier Bills or justify refusal to consider provisional release. The request for provisional release must instead be considered under the law applicable to those imports; upon satisfaction of imposed conditions, the goods are to be released provisionally, without prejudice to independent adjudication proceedings.
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