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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Pre-arrest bail was considered unavailable for alleged misappropriation of funds entrusted for GST payments and alleged use of fabricated GST payment documents. Substantial sums received for GST payment were allegedly not deposited through the GST portal, while forged forms were allegedly produced to create a false appearance of payment. The seriousness of the alleged conduct, involving entrusted funds and fabricated GST records, was treated as sufficient to deny anticipatory protection.
Pre-arrest bail was considered unavailable for alleged misappropriation of funds entrusted for GST payments and alleged use of fabricated GST payment documents. Substantial sums received for GST payment were allegedly not deposited through the GST portal, while forged forms were allegedly produced to create a false appearance of payment. The seriousness of the alleged conduct, involving entrusted funds and fabricated GST records, was treated as sufficient to deny anticipatory protection.
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