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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The customs prohibition on direct or indirect import and transit applies to goods entering India solely for onward transhipment because they retain their character as imported goods until clearance for home consumption. Domestic customs law governs where it directly regulates import and transit; the India-Nepal transhipment treaty does not displace a prohibition and preserves measures concerning prohibited imports and security interests. DRI officers have all-India jurisdiction and may inspect a consignment at its first Indian port of arrival. Conflicting documents and bag labels concerning origin require determination through statutory procedures, and a composite consignment should not be bifurcated pending that determination.
The customs prohibition on direct or indirect import and transit applies to goods entering India solely for onward transhipment because they retain their character as imported goods until clearance for home consumption. Domestic customs law governs where it directly regulates import and transit; the India-Nepal transhipment treaty does not displace a prohibition and preserves measures concerning prohibited imports and security interests. DRI officers have all-India jurisdiction and may inspect a consignment at its first Indian port of arrival. Conflicting documents and bag labels concerning origin require determination through statutory procedures, and a composite consignment should not be bifurcated pending that determination.
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