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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Section 45 PMLA bail assessment proceeds on broad probabilities rather than a final assessment of innocence. Routing alleged proceeds of crime through an applicant's account, without more, does not conclusively establish participation where the explanation of a co-accused's control cannot be rejected at the bail stage. Section 436A Cr.P.C. provides beneficial, though not absolute, protection against prolonged pre-trial custody under the right to speedy trial. Where detention exceeds half the maximum sentence, delay is not attributable to the applicant, and trial completion is remote, Article 21 requires conditional liberty despite the seriousness or pendency of predicate proceedings. Regular bail was granted subject to conditions because continued detention had become punitive.
Section 45 PMLA bail assessment proceeds on broad probabilities rather than a final assessment of innocence. Routing alleged proceeds of crime through an applicant's account, without more, does not conclusively establish participation where the explanation of a co-accused's control cannot be rejected at the bail stage. Section 436A Cr.P.C. provides beneficial, though not absolute, protection against prolonged pre-trial custody under the right to speedy trial. Where detention exceeds half the maximum sentence, delay is not attributable to the applicant, and trial completion is remote, Article 21 requires conditional liberty despite the seriousness or pendency of predicate proceedings. Regular bail was granted subject to conditions because continued detention had become punitive.
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