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...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Section 129 confines detention of goods to the period of transit and does not support detention after the vehicle has reached the consignee's registered premises. A promptly corrected Part-B omission in an e-way bill, supported by valid invoices and Part-A details, was treated as a minor procedural lapse that could not justify detention or penalty absent revenue loss or evidence of intent to evade tax. An adjudication order dated before the personal hearing breached audi alteram partem by rendering the hearing ineffective. The detention, tax demand and penalty were set aside, with refund of amounts collected under protest and applicable statutory interest.
Section 129 confines detention of goods to the period of transit and does not support detention after the vehicle has reached the consignee's registered premises. A promptly corrected Part-B omission in an e-way bill, supported by valid invoices and Part-A details, was treated as a minor procedural lapse that could not justify detention or penalty absent revenue loss or evidence of intent to evade tax. An adjudication order dated before the personal hearing breached audi alteram partem by rendering the hearing ineffective. The detention, tax demand and penalty were set aside, with refund of amounts collected under protest and applicable statutory interest.
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