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...
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...
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Attachment under the Prevention of Money Laundering Act did not prevent a co-operative housing society from redeveloping its building where the attached flat's replacement remained subject to attachment. The attachment had to be disclosed in redevelopment documents, and all accruals relating to the attached flat had to be deposited exclusively in the designated Enforcement Directorate account. The replacement flat was entitled to the same redevelopment benefits as other members. A bank guarantee was not required because it would impose financial pressure before redevelopment terms were finalised. Redevelopment was permitted subject to these safeguards.
Attachment under the Prevention of Money Laundering Act did not prevent a co-operative housing society from redeveloping its building where the attached flat's replacement remained subject to attachment. The attachment had to be disclosed in redevelopment documents, and all accruals relating to the attached flat had to be deposited exclusively in the designated Enforcement Directorate account. The replacement flat was entitled to the same redevelopment benefits as other members. A bank guarantee was not required because it would impose financial pressure before redevelopment terms were finalised. Redevelopment was permitted subject to these safeguards.
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