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...
Protective assessment of seized jewellery requires independent evidence that the person in physical possession is its actual or beneficial owner where the same jewellery has been substantively assessed in the hands of a company claiming ownership. Physical possession and inability to prove another person's ownership do not displace the Revenue's substantive treatment when the individual consistently denies ownership and no positive material establishes ownership. Failure to pursue a first appeal does not cure the absence of evidence or transform a protective addition into a substantive charge. The protective addition for unexplained jewellery was deleted, and consequential interest was to be recomputed.
Protective assessment of seized jewellery requires independent evidence that the person in physical possession is its actual or beneficial owner where the same jewellery has been substantively assessed in the hands of a company claiming ownership. Physical possession and inability to prove another person's ownership do not displace the Revenue's substantive treatment when the individual consistently denies ownership and no positive material establishes ownership. Failure to pursue a first appeal does not cure the absence of evidence or transform a protective addition into a substantive charge. The protective addition for unexplained jewellery was deleted, and consequential interest was to be recomputed.
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