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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Omission of GST Rule 96(10) without a saving clause or statutory mechanism preserving earlier action prevents pending proceedings under the omitted rule from continuing. Applying the Supreme Court principle in Good Luck India Limited, proceedings founded on Rule 96(10) were vitiated following its omission. The impugned orders were set aside, while respondents remained free to take appropriate measures as permitted by law.
Omission of GST Rule 96(10) without a saving clause or statutory mechanism preserving earlier action prevents pending proceedings under the omitted rule from continuing. Applying the Supreme Court principle in Good Luck India Limited, proceedings founded on Rule 96(10) were vitiated following its omission. The impugned orders were set aside, while respondents remained free to take appropriate measures as permitted by law.
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