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...
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
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