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...
Related-party interest expenditure may be disallowed only to the extent it is excessive compared with fair market value; where the interest on an unsecured related-party loan is not excessive, the related expenditure is not disallowable. The provision does not permit a corresponding adjustment by taxing notional interest income from a related party, and separate loan and current accounts cannot be consolidated merely because they involve the same party. Employees' PF and ESI contributions paid after the prescribed due date remain disallowable. Claims for related-party software services, maintenance and brokerage require adequate evidence of the services or facilitation actually provided; unsupported claims fail the genuineness test.
Related-party interest expenditure may be disallowed only to the extent it is excessive compared with fair market value; where the interest on an unsecured related-party loan is not excessive, the related expenditure is not disallowable. The provision does not permit a corresponding adjustment by taxing notional interest income from a related party, and separate loan and current accounts cannot be consolidated merely because they involve the same party. Employees' PF and ESI contributions paid after the prescribed due date remain disallowable. Claims for related-party software services, maintenance and brokerage require adequate evidence of the services or facilitation actually provided; unsupported claims fail the genuineness test.
Note: It is a system-generated summary and is for quick reference only.