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...
Foreign exchange fluctuation loss on year-end restatement of an external commercial borrowing used to acquire capital assets remains in the capital field. The notes state that, although the borrowing from the parent company was subsequently converted into equity shares, the loss retained its capital character because the borrowing was obtained for capital assets. Following earlier Tribunal orders in the same taxpayer's case, the loss could not be claimed as business expenditure under the Act. The disallowance was sustained and the appeal was dismissed.
Foreign exchange fluctuation loss on year-end restatement of an external commercial borrowing used to acquire capital assets remains in the capital field. The notes state that, although the borrowing from the parent company was subsequently converted into equity shares, the loss retained its capital character because the borrowing was obtained for capital assets. Following earlier Tribunal orders in the same taxpayer's case, the loss could not be claimed as business expenditure under the Act. The disallowance was sustained and the appeal was dismissed.
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