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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Natural justice in ex parte GST adjudication required fresh consideration where medical records substantiated the proprietor's pregnancy and consequent inability to participate. Expiry of the statutory appellate limitation left no appellate remedy. The ex parte GST demand was set aside subject to deposit of 10% of the tax demanded and remitted from the reply-and-document-production stage, with a reasonable opportunity of hearing. Non-appearance as directed would automatically revive the earlier order.
Natural justice in ex parte GST adjudication required fresh consideration where medical records substantiated the proprietor's pregnancy and consequent inability to participate. Expiry of the statutory appellate limitation left no appellate remedy. The ex parte GST demand was set aside subject to deposit of 10% of the tax demanded and remitted from the reply-and-document-production stage, with a reasonable opportunity of hearing. Non-appearance as directed would automatically revive the earlier order.
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