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...
GST refund appeals involving an identical question of law must be transferred from different State Benches to the Principal Bench when the President is satisfied that the notification's transfer condition is met. The shared issue concerns refund of interest paid on the part of GST liability discharged through the electronic credit ledger after retrospective substitution of the proviso to section 50(1). Because all eight appeals raised that same issue, the transfer condition was met; the applications were allowed and the appeals were directed to be listed before a Division Bench of the Principal Bench, GSTAT.
GST refund appeals involving an identical question of law must be transferred from different State Benches to the Principal Bench when the President is satisfied that the notification's transfer condition is met. The shared issue concerns refund of interest paid on the part of GST liability discharged through the electronic credit ledger after retrospective substitution of the proviso to section 50(1). Because all eight appeals raised that same issue, the transfer condition was met; the applications were allowed and the appeals were directed to be listed before a Division Bench of the Principal Bench, GSTAT.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
