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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Ex parte GST assessment is addressed where statutory appellate limitation prevents appellate recourse. Fresh consideration is contemplated because the demand was made ex parte, provided the taxpayer files a reply to the show-cause notice, treats the impugned order as an addendum, and makes pre-deposit of the disputed tax. The respondent must then decide the matter on merits after hearing the taxpayer. Non-compliance permits proceedings in accordance with law as though the writ petition had been dismissed in limine.
Ex parte GST assessment is addressed where statutory appellate limitation prevents appellate recourse. Fresh consideration is contemplated because the demand was made ex parte, provided the taxpayer files a reply to the show-cause notice, treats the impugned order as an addendum, and makes pre-deposit of the disputed tax. The respondent must then decide the matter on merits after hearing the taxpayer. Non-compliance permits proceedings in accordance with law as though the writ petition had been dismissed in limine.
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