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...
The High Court upheld conviction u/s 138 of the Negotiable Instruments Act, as presumption u/s 139 favored the complainant. Petitioner's personal cheque dishonored, complying with Act's provisions. Trial and Appellate Court's findings affirmed. However, sentencing of Rs. 1,00,000 compensation or 12 months' imprisonment not in line with law. Citing Krishan Gupta case, compensation not part of sentence but additional to it. HC modified the sentence to align with law, requiring payment within 30 days or face 12-month imprisonment. Application disposed of.
The High Court upheld conviction u/s 138 of the Negotiable Instruments Act, as presumption u/s 139 favored the complainant. Petitioner's personal cheque dishonored, complying with Act's provisions. Trial and Appellate Court's findings affirmed. However, sentencing of Rs. 1,00,000 compensation or 12 months' imprisonment not in line with law. Citing Krishan Gupta case, compensation not part of sentence but additional to it. HC modified the sentence to align with law, requiring payment within 30 days or face 12-month imprisonment. Application disposed of.
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