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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Possession of unused premises in a non-operational Special...
Arbitration of SEZ sub-lease monetary claims preserves rent, maintenance, termination, improvements and damages disputes while unused premises are vacated.
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Possession of unused premises in a non-operational Special Economic Zone unit was separated from the parties' monetary claims to facilitate use by a viable entrepreneur. The applicable rent-control, Special Economic Zone, or public-premises eviction regime was treated as academic and left open. Claims for rent, maintenance, termination, improvements and damages were referred to arbitration, while the respondent was required to vacate after supervised removal of movables and evaluation of improvements.
Possession of unused premises in a non-operational Special Economic Zone unit was separated from the parties' monetary claims to facilitate use by a viable entrepreneur. The applicable rent-control, Special Economic Zone, or public-premises eviction regime was treated as academic and left open. Claims for rent, maintenance, termination, improvements and damages were referred to arbitration, while the respondent was required to vacate after supervised removal of movables and evaluation of improvements.
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