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...
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Confiscation in rem may validly apply to foreign-origin goods concealed in an import consignment that remain uncleared for home consumption, regardless of whether the named consignee qualifies as an importer. Personal penalties under sections 112(a) and 114AA require evidence that the consignee or partner ordered the goods, committed or abetted the offending act, or knowingly used a false declaration. Naming in a bill of lading alone does not establish importer status or knowledge. Untested witness statements and electronic correspondence lacking statutory proof cannot sustain penalties; confiscation remained valid while penalties were set aside.
Confiscation in rem may validly apply to foreign-origin goods concealed in an import consignment that remain uncleared for home consumption, regardless of whether the named consignee qualifies as an importer. Personal penalties under sections 112(a) and 114AA require evidence that the consignee or partner ordered the goods, committed or abetted the offending act, or knowingly used a false declaration. Naming in a bill of lading alone does not establish importer status or knowledge. Untested witness statements and electronic correspondence lacking statutory proof cannot sustain penalties; confiscation remained valid while penalties were set aside.
Note: It is a system-generated summary and is for quick reference only.
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