Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure.
Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure.
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