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...
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Bail in a CGST prosecution involving alleged diversion of online-gaming merchant funds was granted because pre-conviction detention is not punitive and must secure attendance at trial. Completed investigation, filing of the complaint, documentary evidence, Magistrate-triable offences, and absence of criminal antecedents or material showing witness tampering, flight risk, repeat offending, or exceptional circumstances meant continued custody was unjustified. Delay likely to prevent trial completion within a reasonable time further supported release, subject to attendance and non-interference safeguards.
Bail in a CGST prosecution involving alleged diversion of online-gaming merchant funds was granted because pre-conviction detention is not punitive and must secure attendance at trial. Completed investigation, filing of the complaint, documentary evidence, Magistrate-triable offences, and absence of criminal antecedents or material showing witness tampering, flight risk, repeat offending, or exceptional circumstances meant continued custody was unjustified. Delay likely to prevent trial completion within a reasonable time further supported release, subject to attendance and non-interference safeguards.
Note: It is a system-generated summary and is for quick reference only.