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...
Export NOCs limited to specified destinations did not authorise diversion of Tramadol to Pakistan through overseas intermediaries. Email communications and other material established that the intermediaries routed exports to Pakistan and that the appellant company knew of and participated in the arrangement, supporting the money-laundering finding and confirmation of provisional attachment of proceeds of crime. Statutory valuation of attached property required its fair market value on the acquisition date, with the sale deed as material evidence; a later valuation report could not replace that measure. Attachment remained limited to proceeds of crime attributable to the company, and the challenge was dismissed.
Export NOCs limited to specified destinations did not authorise diversion of Tramadol to Pakistan through overseas intermediaries. Email communications and other material established that the intermediaries routed exports to Pakistan and that the appellant company knew of and participated in the arrangement, supporting the money-laundering finding and confirmation of provisional attachment of proceeds of crime. Statutory valuation of attached property required its fair market value on the acquisition date, with the sale deed as material evidence; a later valuation report could not replace that measure. Attachment remained limited to proceeds of crime attributable to the company, and the challenge was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
