Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Reference made to TPO - Transfer Price Adjustments (TPA) – Whether Section 92C and 92CA of the income tax act are independent of each other – the words "the said international transaction under section 92C" do not, lead to the conclusion that the requirement of section 92C(3) can be read into section 92CA(1) of the Act - AT
Reference made to TPO - Transfer Price Adjustments (TPA) – Whether Section 92C and 92CA of the income tax act are independent of each other – the words "the said international transaction under section 92C" do not, lead to the conclusion that the requirement of section 92C(3) can be read into section 92CA(1) of the Act - AT
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