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...
Deduction of tax at source under section 194J is not conclusive of professional income; tax authorities must independently examine the true nature of receipts before denying presumptive taxation under section 44AD. In the cited matter, the Tribunal set aside the appellate order and restored the case for fresh examination and de novo assessment because the receipts had been treated solely on the basis of the payer's TDS deduction, without an independent enquiry, and the assessee was to be given a reasonable opportunity of hearing.
Deduction of tax at source under section 194J is not conclusive of professional income; tax authorities must independently examine the true nature of receipts before denying presumptive taxation under section 44AD. In the cited matter, the Tribunal set aside the appellate order and restored the case for fresh examination and de novo assessment because the receipts had been treated solely on the basis of the payer's TDS deduction, without an independent enquiry, and the assessee was to be given a reasonable opportunity of hearing.
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