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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Timely payment under section 28(6)(i) statutorily concludes all matters stated in a customs show-cause notice, except proceedings expressly preserved. On that reading, proceedings concerning provisionally released imported goods cannot continue selectively for confiscation, redemption fine or penalty under section 114A after statutory conclusion. Redemption fine requires a valid confiscation order, while the proviso to section 125 regulates an existing confiscation power and cannot revive a power already brought to an end. Precedent concerning provisionally released goods does not determine the consequence of statutory conclusion under section 28(6)(i).
Timely payment under section 28(6)(i) statutorily concludes all matters stated in a customs show-cause notice, except proceedings expressly preserved. On that reading, proceedings concerning provisionally released imported goods cannot continue selectively for confiscation, redemption fine or penalty under section 114A after statutory conclusion. Redemption fine requires a valid confiscation order, while the proviso to section 125 regulates an existing confiscation power and cannot revive a power already brought to an end. Precedent concerning provisionally released goods does not determine the consequence of statutory conclusion under section 28(6)(i).
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