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...
Doctrine of merger did not apply where a statutory appeal against GST registration cancellation was summarily dismissed as time-barred; the original cancellation order therefore remained open to challenge under Articles 226 and 227. HC held that dismissal on limitation did not bar writ relief. On the registrant's bona fide explanation for failing to answer the show-cause notice, HC adopted a justice-oriented approach, quashed the cancellation, and directed restoration conditional on timely filing of returns and payment of outstanding tax, interest and penalty. Relief was confined to the peculiar facts and declared non-precedential.
Doctrine of merger did not apply where a statutory appeal against GST registration cancellation was summarily dismissed as time-barred; the original cancellation order therefore remained open to challenge under Articles 226 and 227. HC held that dismissal on limitation did not bar writ relief. On the registrant's bona fide explanation for failing to answer the show-cause notice, HC adopted a justice-oriented approach, quashed the cancellation, and directed restoration conditional on timely filing of returns and payment of outstanding tax, interest and penalty. Relief was confined to the peculiar facts and declared non-precedential.
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