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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Input tax credit on laptop invoices issued while the supplier was registered is not automatically invalidated by the supplier's subsequent retrospective registration cancellation. Section 16(2)(a) requires supplier registration when the invoice is issued; cancellation governs the Department-supplier relationship and does not retrospectively erase issued invoices or the supplier's earlier tax liability. Where invoices appear in FORM GSTR-2A, the supplier filed FORM GSTR-3B, and tax payment is not alleged to be outstanding, the actual-payment condition is satisfied. Credit cannot be denied on an unalleged or speculative concern about payment correlation.
Input tax credit on laptop invoices issued while the supplier was registered is not automatically invalidated by the supplier's subsequent retrospective registration cancellation. Section 16(2)(a) requires supplier registration when the invoice is issued; cancellation governs the Department-supplier relationship and does not retrospectively erase issued invoices or the supplier's earlier tax liability. Where invoices appear in FORM GSTR-2A, the supplier filed FORM GSTR-3B, and tax payment is not alleged to be outstanding, the actual-payment condition is satisfied. Credit cannot be denied on an unalleged or speculative concern about payment correlation.
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