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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Customs valuation of used printing machinery requires reliable, corroborated evidence before declared import values may be displaced. Overseas information lacking import-specific details, verified enquiry material, or supported technical valuation methodology does not establish undervaluation. Confiscation requires a distinct statutory notice; a duty-demand notice cannot substitute for it. Redemption fine cannot be imposed where previously cleared goods are unavailable for confiscation. Differential duty on provisionally assessed goods requires finalisation of the provisional assessment first. Extended limitation requires supported suppression and cannot apply where Customs examined the goods and considered valuation certificates. When valuation demands and confiscation fail, related redemption fines and penalties lack foundation.
Customs valuation of used printing machinery requires reliable, corroborated evidence before declared import values may be displaced. Overseas information lacking import-specific details, verified enquiry material, or supported technical valuation methodology does not establish undervaluation. Confiscation requires a distinct statutory notice; a duty-demand notice cannot substitute for it. Redemption fine cannot be imposed where previously cleared goods are unavailable for confiscation. Differential duty on provisionally assessed goods requires finalisation of the provisional assessment first. Extended limitation requires supported suppression and cannot apply where Customs examined the goods and considered valuation certificates. When valuation demands and confiscation fail, related redemption fines and penalties lack foundation.
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