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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Section 37 of the NDPS Act imposes cumulative conditions for bail in commercial-quantity offences: after the Public Prosecutor has an opportunity to oppose, the court must record reasonable grounds that the accused is not guilty and is unlikely to commit an offence while on bail. General bail considerations and Article 21 concerns, including prolonged custody and trial delay, remain relevant but do not replace this statutory inquiry. Non-recovery, procedural objections, or exclusion of inadmissible statements cannot alone satisfy either condition; the available record requires broad assessment. For foreign nationals in commercial-quantity matters, verified sureties, passport deposit and other enforceable safeguards may be required, while technological tracking must remain proportionate.
Section 37 of the NDPS Act imposes cumulative conditions for bail in commercial-quantity offences: after the Public Prosecutor has an opportunity to oppose, the court must record reasonable grounds that the accused is not guilty and is unlikely to commit an offence while on bail. General bail considerations and Article 21 concerns, including prolonged custody and trial delay, remain relevant but do not replace this statutory inquiry. Non-recovery, procedural objections, or exclusion of inadmissible statements cannot alone satisfy either condition; the available record requires broad assessment. For foreign nationals in commercial-quantity matters, verified sureties, passport deposit and other enforceable safeguards may be required, while technological tracking must remain proportionate.
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