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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Payment of the prescribed appellate pre-deposit and filing of an appeal before the Tribunal trigger a deemed stay of recovery of the balance disputed GST demand under section 112(9), read with the CBIC Circular. During that statutory stay, net eligible GST refunds cannot be appropriated against the stayed demands. Appropriation of refunds for July to September 2023 against demands for financial years 2017-18 to 2019-20 was therefore impermissible, requiring restoration of the net eligible refund while the pending appeals proceed independently on merits.
Payment of the prescribed appellate pre-deposit and filing of an appeal before the Tribunal trigger a deemed stay of recovery of the balance disputed GST demand under section 112(9), read with the CBIC Circular. During that statutory stay, net eligible GST refunds cannot be appropriated against the stayed demands. Appropriation of refunds for July to September 2023 against demands for financial years 2017-18 to 2019-20 was therefore impermissible, requiring restoration of the net eligible refund while the pending appeals proceed independently on merits.
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