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...
Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.
Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.
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TaxTMI 
TaxTMI 
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