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...
Binding interim judicial directions on tax deduction for leave travel concession payments involving foreign travel are described as prevailing over the employer's statutory withholding obligation during their operation. Although a later Supreme Court ruling clarified that leave travel concession with a foreign leg was not exempt, the notes state that this ruling could not retrospectively impose default liability on an employer that complied with the interim directions. The employer was therefore not treated as an assessee in default, and consequential interest did not survive; demands for tax and interest were deleted.
Binding interim judicial directions on tax deduction for leave travel concession payments involving foreign travel are described as prevailing over the employer's statutory withholding obligation during their operation. Although a later Supreme Court ruling clarified that leave travel concession with a foreign leg was not exempt, the notes state that this ruling could not retrospectively impose default liability on an employer that complied with the interim directions. The employer was therefore not treated as an assessee in default, and consequential interest did not survive; demands for tax and interest were deleted.
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