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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GST limitation under Section 74 turns on issuance of substantive show-cause notices and adjudication orders, while Rule 142 requires consequential electronic summaries in Forms GST DRC-01 and DRC-07. Later dates on those forms do not invalidate notices or Orders-in-Original issued within the applicable limitation period. Challenges involving fraud, suppression, supplier knowledge or collusion, input tax credit entitlement, and departmental evidence require statutory appellate scrutiny where no denial of hearing or patent jurisdictional defect exists. Merits remain open before the Appellate Authority.
GST limitation under Section 74 turns on issuance of substantive show-cause notices and adjudication orders, while Rule 142 requires consequential electronic summaries in Forms GST DRC-01 and DRC-07. Later dates on those forms do not invalidate notices or Orders-in-Original issued within the applicable limitation period. Challenges involving fraud, suppression, supplier knowledge or collusion, input tax credit entitlement, and departmental evidence require statutory appellate scrutiny where no denial of hearing or patent jurisdictional defect exists. Merits remain open before the Appellate Authority.
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