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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Refund of unutilised input tax credit under the inverted duty structure remains available under section 54(3) where accumulation results from higher tax on certain inputs than on output supplies. Circular No. 135/05/2020 does not bar such a claim merely because one principal input and the output supply attract the same tax rate. The refund application must be considered under section 54(3), and time spent pursuing writ proceedings is excluded when calculating the limitation period.
Refund of unutilised input tax credit under the inverted duty structure remains available under section 54(3) where accumulation results from higher tax on certain inputs than on output supplies. Circular No. 135/05/2020 does not bar such a claim merely because one principal input and the output supply attract the same tax rate. The refund application must be considered under section 54(3), and time spent pursuing writ proceedings is excluded when calculating the limitation period.
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