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 107(4) imposes an outer limit on the First Appellate Authority's power to condone delay in GST appeals against cancellation of registration. Constitutional and equitable writ jurisdiction under Article 226 is distinct from statutory appellate jurisdiction and cannot expand that prescribed limit; condonation beyond it is legally unsustainable. Where the Department has implemented appellate orders by restoring cancelled registrations, it alters the affected parties' legal and commercial position. A subsequent departmental challenge to those same orders may become academic and infructuous if no effective relief can be granted without disturbing the restoration, rendering the challenge not maintainable.
Section 107(4) imposes an outer limit on the First Appellate Authority's power to condone delay in GST appeals against cancellation of registration. Constitutional and equitable writ jurisdiction under Article 226 is distinct from statutory appellate jurisdiction and cannot expand that prescribed limit; condonation beyond it is legally unsustainable. Where the Department has implemented appellate orders by restoring cancelled registrations, it alters the affected parties' legal and commercial position. A subsequent departmental challenge to those same orders may become academic and infructuous if no effective relief can be granted without disturbing the restoration, rendering the challenge not maintainable.
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