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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Customs detention regulations prohibit recovery of rent or demurrage on goods detained or seized by Customs. Following reassessment and payment of duty, imported Low Alloy Steel Scrap remained entitled to physical release; delays caused by Customs authorities, a shipping line, or a custodian could not be imposed on the importer. The High Court required the shipping line and custodian to issue delivery orders and release the goods without detention charges, container detention charges, ground rent, or demurrage for the certified detention period, while leaving their inter se claims to be resolved according to law.
Customs detention regulations prohibit recovery of rent or demurrage on goods detained or seized by Customs. Following reassessment and payment of duty, imported Low Alloy Steel Scrap remained entitled to physical release; delays caused by Customs authorities, a shipping line, or a custodian could not be imposed on the importer. The High Court required the shipping line and custodian to issue delivery orders and release the goods without detention charges, container detention charges, ground rent, or demurrage for the certified detention period, while leaving their inter se claims to be resolved according to law.
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