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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Limitation for a GST appeal against cancellation of registration commences only when the adjudication order is communicated to the aggrieved person. Communication must enable access to the appellate remedy, and prescribed modes of service must be strictly followed; rules cannot restrict statutory communication solely to electronic service. Uploading an order on the common GST portal alone does not constitute communication for limitation purposes. The time-barred appellate dismissal was set aside, delay was condoned, and the appeal was remanded for decision on merits without addressing the underlying dispute.
Limitation for a GST appeal against cancellation of registration commences only when the adjudication order is communicated to the aggrieved person. Communication must enable access to the appellate remedy, and prescribed modes of service must be strictly followed; rules cannot restrict statutory communication solely to electronic service. Uploading an order on the common GST portal alone does not constitute communication for limitation purposes. The time-barred appellate dismissal was set aside, delay was condoned, and the appeal was remanded for decision on merits without addressing the underlying dispute.
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