Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Insolvency moratorium does not shield company officers from cheque dishonour prosecution for liability arising before corporate insolvency proceedings...
Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Nil ALP cannot be sustained on a benefit test where a franchise payment is for a composite bundle of rights and services; the transfer pricing addition and the alternate Section 37(1) disallowance were deleted because the arrangement was for business purposes and the taxpayer's earlier-year benchmarking had been accepted. On intra-group services, the nil ALP adjustment was also rejected because agreements, invoices and allocation records showed services were received and the tax authorities could not deny deduction by questioning commercial necessity. For purchase of goods, two comparables were excluded, while inclusion of other comparables, margin computation and working capital adjustment were restored for fresh adjudication.
Nil ALP cannot be sustained on a benefit test where a franchise payment is for a composite bundle of rights and services; the transfer pricing addition and the alternate Section 37(1) disallowance were deleted because the arrangement was for business purposes and the taxpayer's earlier-year benchmarking had been accepted. On intra-group services, the nil ALP adjustment was also rejected because agreements, invoices and allocation records showed services were received and the tax authorities could not deny deduction by questioning commercial necessity. For purchase of goods, two comparables were excluded, while inclusion of other comparables, margin computation and working capital adjustment were restored for fresh adjudication.
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