Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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In the absence of any agreement, arrangement or understanding showing that AMP expenditure was incurred for the associated enterprise's sole benefit, Chapter X could not be invoked and the transfer pricing adjustment on AMP spend was deleted. The Tribunal treated the section 14A grounds as consequential and accepted them accordingly. It also allowed the ground on computation-sheet mistakes and directed the Assessing Officer to correct the computation errors in accordance with law.
In the absence of any agreement, arrangement or understanding showing that AMP expenditure was incurred for the associated enterprise's sole benefit, Chapter X could not be invoked and the transfer pricing adjustment on AMP spend was deleted. The Tribunal treated the section 14A grounds as consequential and accepted them accordingly. It also allowed the ground on computation-sheet mistakes and directed the Assessing Officer to correct the computation errors in accordance with law.
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