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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Board monetary-limit litigation policy permits a departmental GST appeal below the prescribed threshold only where a stated exclusion applies. The recurring-issue or interpretation exclusion requires genuine recurring or wider revenue implications; it does not cover every interpretative dispute, mere disagreement with an appellate order, or a general need to construe a provision. As no recurring or cascading implication was pleaded or established, the Revenue appeal against penalty deletion following Section 128A relief was dismissed as not maintainable. Whether that relief could be granted without the prescribed application remained open.
Board monetary-limit litigation policy permits a departmental GST appeal below the prescribed threshold only where a stated exclusion applies. The recurring-issue or interpretation exclusion requires genuine recurring or wider revenue implications; it does not cover every interpretative dispute, mere disagreement with an appellate order, or a general need to construe a provision. As no recurring or cascading implication was pleaded or established, the Revenue appeal against penalty deletion following Section 128A relief was dismissed as not maintainable. Whether that relief could be granted without the prescribed application remained open.
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