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...
Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient's tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.
Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient's tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.
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