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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Refund of duplicated customs-duty payment may not be denied merely because an ICEGATE challan was not generated for the first payment. Where the importer provides the banking and payment records required by the Public Notice, verification through PAO/e-PAO and ICEGATE falls to the proper officer; an unavailable challan resulting from departmental system failure cannot be imposed as a refund condition. Refunds processed under the procedure for customs-duty refunds attract statutory interest where payment is not made within the prescribed period, at the rate notified by the Government.
Refund of duplicated customs-duty payment may not be denied merely because an ICEGATE challan was not generated for the first payment. Where the importer provides the banking and payment records required by the Public Notice, verification through PAO/e-PAO and ICEGATE falls to the proper officer; an unavailable challan resulting from departmental system failure cannot be imposed as a refund condition. Refunds processed under the procedure for customs-duty refunds attract statutory interest where payment is not made within the prescribed period, at the rate notified by the Government.
Note: It is a system-generated summary and is for quick reference only.