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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Under a GST-inclusive tender, a supplier's statutory obligation to pay GST remains distinct from any contractual right to pass that cost to service recipients. Where tender terms authorise collection only of a prescribed fee inclusive of all taxes, the tender holder cannot separately collect GST from Chendamelam artists. GST paid by the tender holder also does not create a reimbursement obligation for the Devaswom Board unless a tender condition or statutory provision expressly requires reimbursement. Contractual allocation of tax liability therefore governs both recovery from recipients and reimbursement from the contracting body.
Under a GST-inclusive tender, a supplier's statutory obligation to pay GST remains distinct from any contractual right to pass that cost to service recipients. Where tender terms authorise collection only of a prescribed fee inclusive of all taxes, the tender holder cannot separately collect GST from Chendamelam artists. GST paid by the tender holder also does not create a reimbursement obligation for the Devaswom Board unless a tender condition or statutory provision expressly requires reimbursement. Contractual allocation of tax liability therefore governs both recovery from recipients and reimbursement from the contracting body.
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