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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Section 67(2) of the CGST Act is described as not authorising seizure of cash merely because it is suspected to represent unaccounted sale proceeds. Cash is excluded from "goods" and, under an ejusdem generis construction, "things" is confined to material with evidentiary relevance alongside documents and books. Seizure requires objectively supported reasons to believe satisfying statutory conditions; a later adjudicatory finding cannot cure absent authority at the time of seizure. A jurisdictional challenge to such seizure may proceed despite an alternative appellate remedy. Release remains subject to any independently lawful restraint or attachment, with applicable interest.
Section 67(2) of the CGST Act is described as not authorising seizure of cash merely because it is suspected to represent unaccounted sale proceeds. Cash is excluded from "goods" and, under an ejusdem generis construction, "things" is confined to material with evidentiary relevance alongside documents and books. Seizure requires objectively supported reasons to believe satisfying statutory conditions; a later adjudicatory finding cannot cure absent authority at the time of seizure. A jurisdictional challenge to such seizure may proceed despite an alternative appellate remedy. Release remains subject to any independently lawful restraint or attachment, with applicable interest.
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