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...
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
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