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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Writ jurisdiction was not invoked against repeated GST summons that only sought information and documents, where the recipient had already submitted a representation with relevant copies. In the absence of evidence of coercive recovery or a threat of arrest, the summons did not establish a basis for judicial interference. The writ petition was treated as premature and rejected.
Writ jurisdiction was not invoked against repeated GST summons that only sought information and documents, where the recipient had already submitted a representation with relevant copies. In the absence of evidence of coercive recovery or a threat of arrest, the summons did not establish a basis for judicial interference. The writ petition was treated as premature and rejected.
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