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...
Accumulated input tax credit on higher-taxed packaging materials, containers and printed flexible packaging used for packaged tea qualifies for inverted duty structure refund where those inputs bear a higher tax rate than the output supply. Equal tax treatment of bulk tea and packaged tea does not negate the refund where the packaging inputs themselves create the rate inversion. A departmental circular addressing reductions in tax rates on the same goods over time does not apply to this circumstance and cannot restrict a refund otherwise available under the Act. The sanctioned refund is consequently payable.
Accumulated input tax credit on higher-taxed packaging materials, containers and printed flexible packaging used for packaged tea qualifies for inverted duty structure refund where those inputs bear a higher tax rate than the output supply. Equal tax treatment of bulk tea and packaged tea does not negate the refund where the packaging inputs themselves create the rate inversion. A departmental circular addressing reductions in tax rates on the same goods over time does not apply to this circumstance and cannot restrict a refund otherwise available under the Act. The sanctioned refund is consequently payable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
