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...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
MGST offences may be investigated alongside distinct BNS offences arising from the same fraudulent GST transactions. Special-enactment offences remain subject to the Code unless the MGST framework expressly provides otherwise; tax-officer powers and police-assistance provisions do not themselves prohibit police investigation. Parallel prosecution under the MGST regime and general penal law is permissible where each statute addresses distinct offences, while double punishment for the same offence remains barred. On that basis, the FIR alleging both MGST and BNS offences was not quashed and the criminal writ petition was dismissed.
MGST offences may be investigated alongside distinct BNS offences arising from the same fraudulent GST transactions. Special-enactment offences remain subject to the Code unless the MGST framework expressly provides otherwise; tax-officer powers and police-assistance provisions do not themselves prohibit police investigation. Parallel prosecution under the MGST regime and general penal law is permissible where each statute addresses distinct offences, while double punishment for the same offence remains barred. On that basis, the FIR alleging both MGST and BNS offences was not quashed and the criminal writ petition was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
