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...
Tax deduction on foreign-leg Leave Travel Concession reimbursement was not treated as automatically enforceable against an employer where a binding interim judicial direction operated. Deductor liability requires examination of whether beneficiary employees were assessed and discharged their tax liability. Compliance with an interim direction placing eventual tax liability on employees cannot retrospectively create employer default after later determination of taxability. Consequently, demands for non-deduction and interest were deleted. The related penalty failed because it depended solely on the employer being treated as an assessee in default.
Tax deduction on foreign-leg Leave Travel Concession reimbursement was not treated as automatically enforceable against an employer where a binding interim judicial direction operated. Deductor liability requires examination of whether beneficiary employees were assessed and discharged their tax liability. Compliance with an interim direction placing eventual tax liability on employees cannot retrospectively create employer default after later determination of taxability. Consequently, demands for non-deduction and interest were deleted. The related penalty failed because it depended solely on the employer being treated as an assessee in default.
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