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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Pre-CIRP export-obligation defaults cannot support continued Denied Entry List restrictions after an approved, unchallenged resolution plan extinguishes the Government's operational-debt claim and attached performance obligations. Coercive administrative orders issued against the corporate debtor during the insolvency moratorium were void ab initio, and the impugned orders and listing were set aside, subject to fresh lawful action for an independent subsequent default. Inaction by the final decision-making authority constituted part of the cause of action, supporting territorial writ jurisdiction. Availability of an alternative remedy did not oust constitutional writ jurisdiction.
Pre-CIRP export-obligation defaults cannot support continued Denied Entry List restrictions after an approved, unchallenged resolution plan extinguishes the Government's operational-debt claim and attached performance obligations. Coercive administrative orders issued against the corporate debtor during the insolvency moratorium were void ab initio, and the impugned orders and listing were set aside, subject to fresh lawful action for an independent subsequent default. Inaction by the final decision-making authority constituted part of the cause of action, supporting territorial writ jurisdiction. Availability of an alternative remedy did not oust constitutional writ jurisdiction.
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