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...
Corporate guarantee furnished to an associated enterprise for credit facilities was treated as an international transaction because the statutory explanation to section 92B covers capital financing, including guarantees, and the guarantee had a direct bearing on the enterprise's financial position; the transfer pricing challenge on that point failed. For arm's length commission, the Tribunal held that the guarantee exposure changed during the year as the underlying loan was repaid, so the risk assumed could not be measured only by the year-end balance. It sustained computation of commission at 0.50% on the average of opening and closing outstanding exposure, and dismissed the appeals.
Corporate guarantee furnished to an associated enterprise for credit facilities was treated as an international transaction because the statutory explanation to section 92B covers capital financing, including guarantees, and the guarantee had a direct bearing on the enterprise's financial position; the transfer pricing challenge on that point failed. For arm's length commission, the Tribunal held that the guarantee exposure changed during the year as the underlying loan was repaid, so the risk assumed could not be measured only by the year-end balance. It sustained computation of commission at 0.50% on the average of opening and closing outstanding exposure, and dismissed the appeals.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
