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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Compulsory acquisition of land and buildings under the State's eminent-domain power is an expropriation, not a supply of goods or services for GST purposes. Land and buildings attached to land are immovable property, and landowners do not sell goods or provide services merely by surrendering property pursuant to statutory acquisition. GST deducted from compensation for such acquisition therefore lacks statutory basis. The deduction was treated as exceeding legal authority, with the affected compensation notice quashed to that extent and refund of the deducted GST with interest directed.
Compulsory acquisition of land and buildings under the State's eminent-domain power is an expropriation, not a supply of goods or services for GST purposes. Land and buildings attached to land are immovable property, and landowners do not sell goods or provide services merely by surrendering property pursuant to statutory acquisition. GST deducted from compensation for such acquisition therefore lacks statutory basis. The deduction was treated as exceeding legal authority, with the affected compensation notice quashed to that extent and refund of the deducted GST with interest directed.
Note: It is a system-generated summary and is for quick reference only.