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...
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Statutory appellate remedies against tax adjudication orders were permitted despite limitation objections being waived, subject to compliance with the mandatory pre-deposit requirement. Amounts previously deposited towards the disputed tax demand were to be adjusted against the pre-deposit. Upon satisfying that requirement, the statutory stay applied to the remaining disputed demand. Appeals filed within the specified two-week period were to be entertained and decided on merits without a limitation objection.
Statutory appellate remedies against tax adjudication orders were permitted despite limitation objections being waived, subject to compliance with the mandatory pre-deposit requirement. Amounts previously deposited towards the disputed tax demand were to be adjusted against the pre-deposit. Upon satisfying that requirement, the statutory stay applied to the remaining disputed demand. Appeals filed within the specified two-week period were to be entertained and decided on merits without a limitation objection.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
