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...
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Operational debt and default arising from mustard-seed supplies were established through TDS deductions, GST input tax credit and ledger entries showing that goods were supplied and received. An incorrect PIN Code in invoices and e-way bills did not disprove delivery where those records otherwise matched the corporate debtor's registered-office address and no contemporaneous non-supply objection was raised; the non-supply defence was rejected. The corporate debtor's own ledger showed an outstanding balance above the insolvency threshold, so further reconciliation was unnecessary and admission of the insolvency application was upheld.
Operational debt and default arising from mustard-seed supplies were established through TDS deductions, GST input tax credit and ledger entries showing that goods were supplied and received. An incorrect PIN Code in invoices and e-way bills did not disprove delivery where those records otherwise matched the corporate debtor's registered-office address and no contemporaneous non-supply objection was raised; the non-supply defence was rejected. The corporate debtor's own ledger showed an outstanding balance above the insolvency threshold, so further reconciliation was unnecessary and admission of the insolvency application was upheld.
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