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...
Classification of disposable analytical cartridges depends on objective characteristics, functional integration and sole or principal suitability, rather than plastic content or single-use status. The Tribunal classified micro-cuvettes containing magnetically controlled steel balls, designed exclusively for a coagulation analyser, under CTI 9027 9090 as parts or accessories of analytical apparatus, not under residual CTI 3926 9099 for plastic articles. Chapter 90 Note 2 requires first testing whether the item has an independent specified heading under Note 2(a); otherwise, Note 2(b) classifies a dedicated component with the relevant instrument. Residual plastics treatment cannot displace that result.
Classification of disposable analytical cartridges depends on objective characteristics, functional integration and sole or principal suitability, rather than plastic content or single-use status. The Tribunal classified micro-cuvettes containing magnetically controlled steel balls, designed exclusively for a coagulation analyser, under CTI 9027 9090 as parts or accessories of analytical apparatus, not under residual CTI 3926 9099 for plastic articles. Chapter 90 Note 2 requires first testing whether the item has an independent specified heading under Note 2(a); otherwise, Note 2(b) classifies a dedicated component with the relevant instrument. Residual plastics treatment cannot displace that result.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
