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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Entry 34 of List II permits State legislation regulating or prohibiting betting on uncertain outcomes, including outcomes of predominantly skill-based games. The constitutional distinction is between the skill game itself and a wager placed on its uncertain result: a stake, uncertainty and expectation of gain bring the activity within betting and gambling, regardless of the game's skill classification. Genuine participation fees for skill competitions may remain distinct from outcome-linked stakes, requiring examination of the payment's function and the event's structure. Statutory exemptions for wagering on games of skill are matters of legislative policy and may be withdrawn. Online money-gaming restrictions may additionally rely on public order only where a real and proximate connection to community-wide disruption is established. Betting and gambling, as res extra commercium, does not attract proportionality review based on a claimed right to conduct that enterprise.
Entry 34 of List II permits State legislation regulating or prohibiting betting on uncertain outcomes, including outcomes of predominantly skill-based games. The constitutional distinction is between the skill game itself and a wager placed on its uncertain result: a stake, uncertainty and expectation of gain bring the activity within betting and gambling, regardless of the game's skill classification. Genuine participation fees for skill competitions may remain distinct from outcome-linked stakes, requiring examination of the payment's function and the event's structure. Statutory exemptions for wagering on games of skill are matters of legislative policy and may be withdrawn. Online money-gaming restrictions may additionally rely on public order only where a real and proximate connection to community-wide disruption is established. Betting and gambling, as res extra commercium, does not attract proportionality review based on a claimed right to conduct that enterprise.
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