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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Proceedings against a Customs Broker under the Customs Brokers Licensing Regulations were invalid because the mandatory ninety-day period for issuing notice was breached. Where no date of receipt of the offence report was disclosed, the Department's knowledge of the alleged contraventions through its own customs notice, and at the latest their adjudication, constituted the relevant starting point. The regulatory notice was issued beyond the prescribed period even from the later event. The breach vitiated the proceedings, requiring the penalty order to be set aside; the merits of the alleged contraventions remained unexamined.
Proceedings against a Customs Broker under the Customs Brokers Licensing Regulations were invalid because the mandatory ninety-day period for issuing notice was breached. Where no date of receipt of the offence report was disclosed, the Department's knowledge of the alleged contraventions through its own customs notice, and at the latest their adjudication, constituted the relevant starting point. The regulatory notice was issued beyond the prescribed period even from the later event. The breach vitiated the proceedings, requiring the penalty order to be set aside; the merits of the alleged contraventions remained unexamined.
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