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...
Corporate guarantee taxability under GST was remitted for fresh assessment because the assessing authority had not properly considered the petitioner's reliance on applicable GST circulars, the contention that only 1% of turnover was taxable, and the earlier Madras HC ruling cited in support. The Court held that these aspects required examination and that the assessment could not stand on the corporate guarantee issue alone. The impugned order was therefore set aside only to that limited extent, with directions for fresh orders after hearing the petitioner and considering supporting material; all other findings were left undisturbed.
Corporate guarantee taxability under GST was remitted for fresh assessment because the assessing authority had not properly considered the petitioner's reliance on applicable GST circulars, the contention that only 1% of turnover was taxable, and the earlier Madras HC ruling cited in support. The Court held that these aspects required examination and that the assessment could not stand on the corporate guarantee issue alone. The impugned order was therefore set aside only to that limited extent, with directions for fresh orders after hearing the petitioner and considering supporting material; all other findings were left undisturbed.
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