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...
Transfer pricing adjustment – Computation of ALP – Advances made to overseas subsidiaries – The differences are so fundamental that these differences, to use the phraseology employed in Rule 10 B (1)(a)(ii), “could materially affect the price in the open market“ - the application of LIBOR plus rate or, for that purpose, any bank rate will be inappropriate to this case. - AT
Transfer pricing adjustment – Computation of ALP – Advances made to overseas subsidiaries – The differences are so fundamental that these differences, to use the phraseology employed in Rule 10 B (1)(a)(ii), “could materially affect the price in the open market“ - the application of LIBOR plus rate or, for that purpose, any bank rate will be inappropriate to this case. - AT
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