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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Uploading a GST show cause notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, denied the taxpayer an effective opportunity to reply and breached the principles of natural justice. As the statutory appeal was dismissed solely on limitation without consideration on merits, the show cause notice, adjudication order and appellate order were quashed. Fresh proceedings were directed through a fresh show cause notice, an opportunity of hearing, and a reasoned adjudication.
Uploading a GST show cause notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, denied the taxpayer an effective opportunity to reply and breached the principles of natural justice. As the statutory appeal was dismissed solely on limitation without consideration on merits, the show cause notice, adjudication order and appellate order were quashed. Fresh proceedings were directed through a fresh show cause notice, an opportunity of hearing, and a reasoned adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
