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...
Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already reflected in arm's length pricing. Cross-examination, corroboration, and a direct link to the relevant year remain necessary for unexplained-money additions.
Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already reflected in arm's length pricing. Cross-examination, corroboration, and a direct link to the relevant year remain necessary for unexplained-money additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
