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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Section 129DD permits the revisional authority to annul or modify an appellate customs order and, absent an express prohibition, remit confiscation and redemption proceedings for fresh adjudication. Revisional review may correct an appellate finding that overlooks material evidence, including circumstances relevant to a purchase invoice and the claimant's burden to prove lawful import, without finally deciding redemption or confiscation. A separate show-cause notice is required only for enhancement of penalty or fine or confiscation of goods of greater value; it is unnecessary for remand where the affected party has been heard. Statutory revision time limits cannot be enlarged under the Limitation Act, but a limitation challenge fails where the communication date is unproved. The writ petition was dismissed and remand sustained.
Section 129DD permits the revisional authority to annul or modify an appellate customs order and, absent an express prohibition, remit confiscation and redemption proceedings for fresh adjudication. Revisional review may correct an appellate finding that overlooks material evidence, including circumstances relevant to a purchase invoice and the claimant's burden to prove lawful import, without finally deciding redemption or confiscation. A separate show-cause notice is required only for enhancement of penalty or fine or confiscation of goods of greater value; it is unnecessary for remand where the affected party has been heard. Statutory revision time limits cannot be enlarged under the Limitation Act, but a limitation challenge fails where the communication date is unproved. The writ petition was dismissed and remand sustained.
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TaxTMI 
TaxTMI 
