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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Rule 26(3) makes electronic issuance and prescribed authentication cumulative requirements for GST notices, certificates and orders. A digital signature, e-signature or other notified verification mode attributes the instrument to the authorised officer and evidences accountability; portal upload, system-generated reference numbers, DRC summaries and DIN do not substitute for authentication. An unsigned notice or order lacks legal validity, cannot support consequential recovery, and is not ordinarily cured by the saving provision for minor defects. Service through the common portal concerns communication, not the prior validity of the instrument. DRC-01 cannot replace a statutory show-cause notice, while DRC-07 supports recovery only where founded on a valid order. Hearing requirements and effective service remain separate procedural safeguards.
Rule 26(3) makes electronic issuance and prescribed authentication cumulative requirements for GST notices, certificates and orders. A digital signature, e-signature or other notified verification mode attributes the instrument to the authorised officer and evidences accountability; portal upload, system-generated reference numbers, DRC summaries and DIN do not substitute for authentication. An unsigned notice or order lacks legal validity, cannot support consequential recovery, and is not ordinarily cured by the saving provision for minor defects. Service through the common portal concerns communication, not the prior validity of the instrument. DRC-01 cannot replace a statutory show-cause notice, while DRC-07 supports recovery only where founded on a valid order. Hearing requirements and effective service remain separate procedural safeguards.
Note: It is a system-generated summary and is for quick reference only.
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