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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Under the unamended section 129, its link through section 129(6) to section 130 made intent to evade tax necessary before imposing a detention penalty. Transport of traceable motorcycles without an e-way bill did not establish that intent where the e-invoice contained engine and chassis particulars, physical verification found no discrepancy, returns disclosed the transaction, and no finding of evasion existed. The penalty was therefore unsustainable, although lawful procedural action for the documentation lapse remained open. Section 75(4) also required a meaningful hearing; an order issued fifty-seven minutes after the show-cause notice breached natural justice. The penalty orders were set aside and the deposit was refundable with applicable interest.
Under the unamended section 129, its link through section 129(6) to section 130 made intent to evade tax necessary before imposing a detention penalty. Transport of traceable motorcycles without an e-way bill did not establish that intent where the e-invoice contained engine and chassis particulars, physical verification found no discrepancy, returns disclosed the transaction, and no finding of evasion existed. The penalty was therefore unsustainable, although lawful procedural action for the documentation lapse remained open. Section 75(4) also required a meaningful hearing; an order issued fifty-seven minutes after the show-cause notice breached natural justice. The penalty orders were set aside and the deposit was refundable with applicable interest.
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