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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The interaction between the mandatory pre-deposit for a GST appeal and the IBC liquidation framework raises whether a corporate debtor in liquidation may be excused from making that deposit. The issue is whether using liquidation-estate funds for the pre-deposit conflicts with the statutory distribution waterfall governing creditors' claims. The High Court sought assistance on whether liquidation priorities affect the mandatory pre-deposit requirement for filing a GST appeal.
The interaction between the mandatory pre-deposit for a GST appeal and the IBC liquidation framework raises whether a corporate debtor in liquidation may be excused from making that deposit. The issue is whether using liquidation-estate funds for the pre-deposit conflicts with the statutory distribution waterfall governing creditors' claims. The High Court sought assistance on whether liquidation priorities affect the mandatory pre-deposit requirement for filing a GST appeal.
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