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...
Stamp duty on an order approving a scheme of amalgamation must be determined by treating that order as the instrument of levy. Reliance on a share valuation predating the order is not justified solely because the amalgamation order does not specify valuation. However, where neither side adequately establishes the relevant value at the time of scheme submission or order, strict construction of fiscal law requires fresh adjudication based on relevant valuation material and the taxpayer's written response. The stamp-duty demand was set aside, with the matter remanded for fresh adjudication after personal hearing; the interim deposit was to continue pending that determination.
Stamp duty on an order approving a scheme of amalgamation must be determined by treating that order as the instrument of levy. Reliance on a share valuation predating the order is not justified solely because the amalgamation order does not specify valuation. However, where neither side adequately establishes the relevant value at the time of scheme submission or order, strict construction of fiscal law requires fresh adjudication based on relevant valuation material and the taxpayer's written response. The stamp-duty demand was set aside, with the matter remanded for fresh adjudication after personal hearing; the interim deposit was to continue pending that determination.
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