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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Interim moratorium under the Insolvency and Bankruptcy Code no longer applies to personal guarantors of corporate debtors from 26 May 2026, including where insolvency applications were already pending before the Adjudicating Authority. The amendments inserting sub-sections (4) to sections 96 and 124 apply to pending applications: the phrase "is filed" includes applications filed before the effective date that remained under adjudication. Consequently, the moratorium previously protecting such guarantors ceased, and proceedings otherwise barred by section 96 may continue.
Interim moratorium under the Insolvency and Bankruptcy Code no longer applies to personal guarantors of corporate debtors from 26 May 2026, including where insolvency applications were already pending before the Adjudicating Authority. The amendments inserting sub-sections (4) to sections 96 and 124 apply to pending applications: the phrase "is filed" includes applications filed before the effective date that remained under adjudication. Consequently, the moratorium previously protecting such guarantors ceased, and proceedings otherwise barred by section 96 may continue.
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