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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Subscription to and redemption of non-cumulative redeemable preference shares could not be re-characterised as an unsecured loan for transfer pricing purposes in the absence of material showing a sham or concealment of the real transaction; with only an opening balance and minor redemption, the notional interest adjustment was deleted. On advances to subsidiaries, the assessee's substantial own funds and interest-free funds exceeded the advances, so the presumption applied that the advances came from own funds rather than borrowed funds, and the interest disallowance was deleted. The Revenue's appeal was dismissed.
Subscription to and redemption of non-cumulative redeemable preference shares could not be re-characterised as an unsecured loan for transfer pricing purposes in the absence of material showing a sham or concealment of the real transaction; with only an opening balance and minor redemption, the notional interest adjustment was deleted. On advances to subsidiaries, the assessee's substantial own funds and interest-free funds exceeded the advances, so the presumption applied that the advances came from own funds rather than borrowed funds, and the interest disallowance was deleted. The Revenue's appeal was dismissed.
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