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...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
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Retention of seized jewellery under PMLA was sustained because interlinked accounts, fund movements and jewellery payments supplied a prima facie nexus with proceeds of crime. The inquiry may cover property held by a person not accused of the scheduled offence where the property is connected with, or requires examination regarding, such proceeds. Recovery from a joint family residence and lack of transaction-wise tracing for individual items did not negate the nexus. Defective initial service of notice did not invalidate adjudication because participation and opportunity to defend caused no identified prejudice.
Retention of seized jewellery under PMLA was sustained because interlinked accounts, fund movements and jewellery payments supplied a prima facie nexus with proceeds of crime. The inquiry may cover property held by a person not accused of the scheduled offence where the property is connected with, or requires examination regarding, such proceeds. Recovery from a joint family residence and lack of transaction-wise tracing for individual items did not negate the nexus. Defective initial service of notice did not invalidate adjudication because participation and opportunity to defend caused no identified prejudice.
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