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...
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
