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...
Provisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operation of law one year after the attachment order. Continued freezing cannot rest on an expired attachment where no fresh provisional attachment order has been issued. Where account holders were not recipients of a later demand-cum-show cause notice, that notice did not provide a basis to maintain restrictions on their accounts. The lapsed attachments required the bank accounts to be defreezed and made operable upon production of a certified copy of the order.
Provisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operation of law one year after the attachment order. Continued freezing cannot rest on an expired attachment where no fresh provisional attachment order has been issued. Where account holders were not recipients of a later demand-cum-show cause notice, that notice did not provide a basis to maintain restrictions on their accounts. The lapsed attachments required the bank accounts to be defreezed and made operable upon production of a certified copy of the order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
