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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Regulation 13(7) requires communication of an insolvency professional's disciplinary order to committees of creditors and adjudicating authorities in other ongoing CIRPs. The interim approach described treats that intimation as enabling each committee to decide whether to continue or replace the professional, rather than automatically disqualifying the professional from unrelated assignments. Proportionality and audi alteram partem require that cross-assignment consequences have a disclosed factual basis and an opportunity to respond. The Board retains disciplinary powers, while committees retain their statutory replacement role. Other appellate rulings take the contrary view that suspension of registration makes the professional ineligible across all assignments. Final appellate review and the underlying disciplinary findings remain open.
Regulation 13(7) requires communication of an insolvency professional's disciplinary order to committees of creditors and adjudicating authorities in other ongoing CIRPs. The interim approach described treats that intimation as enabling each committee to decide whether to continue or replace the professional, rather than automatically disqualifying the professional from unrelated assignments. Proportionality and audi alteram partem require that cross-assignment consequences have a disclosed factual basis and an opportunity to respond. The Board retains disciplinary powers, while committees retain their statutory replacement role. Other appellate rulings take the contrary view that suspension of registration makes the professional ineligible across all assignments. Final appellate review and the underlying disciplinary findings remain open.
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