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 129(3) of the CGST Act imposes a mandatory two-stage deadline: a penalty notice must issue within seven days of detention or seizure, followed by a penalty order within seven days of service. Breach of either period, including a one-day delay, invalidates the detention adjudication; later confiscation action cannot retrospectively cure it, although independently authorised proceedings may remain available. Service, including portal availability under Section 169, determines the second period, while Rule 142 requires corresponding electronic summaries. A hearing is required before penalty determination. Payment to obtain release, particularly under protest after objections, does not itself waive a challenge; a reasoned order remains necessary to preserve appellate access.
Section 129(3) of the CGST Act imposes a mandatory two-stage deadline: a penalty notice must issue within seven days of detention or seizure, followed by a penalty order within seven days of service. Breach of either period, including a one-day delay, invalidates the detention adjudication; later confiscation action cannot retrospectively cure it, although independently authorised proceedings may remain available. Service, including portal availability under Section 169, determines the second period, while Rule 142 requires corresponding electronic summaries. A hearing is required before penalty determination. Payment to obtain release, particularly under protest after objections, does not itself waive a challenge; a reasoned order remains necessary to preserve appellate access.
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