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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Revised Customs prosecution thresholds for precious-metal smuggling may extend to pending complaints if the goods' value is below the updated limit. The later circular changes only the monetary threshold and preserves the earlier circular's other conditions. Neither circular prohibits consideration of withdrawal after prosecution sanction has issued; the Magistrate retains discretion under the earlier framework to decide whether the prosecution should continue. Where withdrawal was rejected solely because sanction had issued, reconsideration under the applicable circulars is required.
Revised Customs prosecution thresholds for precious-metal smuggling may extend to pending complaints if the goods' value is below the updated limit. The later circular changes only the monetary threshold and preserves the earlier circular's other conditions. Neither circular prohibits consideration of withdrawal after prosecution sanction has issued; the Magistrate retains discretion under the earlier framework to decide whether the prosecution should continue. Where withdrawal was rejected solely because sanction had issued, reconsideration under the applicable circulars is required.
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TaxTMI 
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