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...
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Parallel criminal acquittal for failure to prove penal ingredients does not by itself negate an independently acknowledged financial liability supporting cheque dishonour proceedings. A notarized agreement and written declaration may establish a legally enforceable debt. Once foundational facts are proved, presumptions of consideration and discharge arise and require a probable, material-supported defence; an uncorroborated snatched-cheque assertion without a contemporaneous police complaint or bank intimation is insufficient. Registered dispatch to the drawer's correct address supports due service of the statutory demand notice, while revisional review remains limited to perversity, lack of evidence, or material legal or procedural error.
Parallel criminal acquittal for failure to prove penal ingredients does not by itself negate an independently acknowledged financial liability supporting cheque dishonour proceedings. A notarized agreement and written declaration may establish a legally enforceable debt. Once foundational facts are proved, presumptions of consideration and discharge arise and require a probable, material-supported defence; an uncorroborated snatched-cheque assertion without a contemporaneous police complaint or bank intimation is insufficient. Registered dispatch to the drawer's correct address supports due service of the statutory demand notice, while revisional review remains limited to perversity, lack of evidence, or material legal or procedural error.
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TaxTMI 
TaxTMI 
