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...
Release of detained cargo containers required resolution of unpaid de-stuffing charges because the no-objection communication applied only to empty containers. Once it was confirmed that the containers held cargo requiring removal, neither private party agreed to pay those charges. The importer, whose appeal was pending before CESTAT, was a proper and necessary party but had not been joined. The parties were left to seek appropriate orders from the authorities for de-stuffing and release of the containers after notice to the importer.
Release of detained cargo containers required resolution of unpaid de-stuffing charges because the no-objection communication applied only to empty containers. Once it was confirmed that the containers held cargo requiring removal, neither private party agreed to pay those charges. The importer, whose appeal was pending before CESTAT, was a proper and necessary party but had not been joined. The parties were left to seek appropriate orders from the authorities for de-stuffing and release of the containers after notice to the importer.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
