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...
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Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.
Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.
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