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...
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Section 62(2) of the GST law provides for deemed withdrawal of a best-judgment assessment when the requisite GSTR-3B return is filed. Delayed filing does not prevent that statutory benefit where the applicable late fee is also paid, following the amendment permitting condonation of delay in return filing. Once the assessment is deemed withdrawn, the tax demand and related dues under that assessment cannot be recovered, and recovery proceedings cannot be initiated or continued on its basis.
Section 62(2) of the GST law provides for deemed withdrawal of a best-judgment assessment when the requisite GSTR-3B return is filed. Delayed filing does not prevent that statutory benefit where the applicable late fee is also paid, following the amendment permitting condonation of delay in return filing. Once the assessment is deemed withdrawn, the tax demand and related dues under that assessment cannot be recovered, and recovery proceedings cannot be initiated or continued on its basis.
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