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...
Non-reporting of an international transaction may attract penalty under section 271AA, but a bona fide belief based on reasonable cause can exclude liability where the transaction has no effective nexus with an Indian project office or permanent establishment, no related income is attributed to India, and the transaction is accepted at arm's length. The notes state that penalty for a Korean sale of raw materials to an Indian associated enterprise was deleted on this basis. They further explain that appellate enhancement cannot introduce transactions outside the scope of the original penalty proceedings. Enhancement relating to guarantee fees and trade affairs services was therefore unsustainable because initiation had concerned only the raw-material sale.
Non-reporting of an international transaction may attract penalty under section 271AA, but a bona fide belief based on reasonable cause can exclude liability where the transaction has no effective nexus with an Indian project office or permanent establishment, no related income is attributed to India, and the transaction is accepted at arm's length. The notes state that penalty for a Korean sale of raw materials to an Indian associated enterprise was deleted on this basis. They further explain that appellate enhancement cannot introduce transactions outside the scope of the original penalty proceedings. Enhancement relating to guarantee fees and trade affairs services was therefore unsustainable because initiation had concerned only the raw-material sale.
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