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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Section 112(1) confines Tribunal appeals to orders made in first appeal or revision; an original adjudication order remains outside that jurisdiction even where a statutory first appeal is pending. Presentation defects involving the respondent, supporting documents or deposit do not remedy the absence of an appealable order or allow a filing to be retained pending a future first-appellate order. A direct Tribunal challenge to the original order is therefore not maintainable, while the merits of the demand, the pending first appeal and recovery remain unresolved.
Section 112(1) confines Tribunal appeals to orders made in first appeal or revision; an original adjudication order remains outside that jurisdiction even where a statutory first appeal is pending. Presentation defects involving the respondent, supporting documents or deposit do not remedy the absence of an appealable order or allow a filing to be retained pending a future first-appellate order. A direct Tribunal challenge to the original order is therefore not maintainable, while the merits of the demand, the pending first appeal and recovery remain unresolved.
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