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...
Appellate directions affirmed by the Supreme Court bind the parties and cannot be indirectly challenged through appeals against consequential compliance orders. Orders that merely implement or reiterate directions for fresh consideration, preserve existing interim arrangements, and neither decide the merits nor create new findings affecting rights do not warrant appellate interference. The Tribunal dismissed the connected appeals because they sought to reopen a prior appellate determination that had attained finality.
Appellate directions affirmed by the Supreme Court bind the parties and cannot be indirectly challenged through appeals against consequential compliance orders. Orders that merely implement or reiterate directions for fresh consideration, preserve existing interim arrangements, and neither decide the merits nor create new findings affecting rights do not warrant appellate interference. The Tribunal dismissed the connected appeals because they sought to reopen a prior appellate determination that had attained finality.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
