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...
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
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