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...
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
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