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...
Capital receipt not chargeable to tax - bifurcation of income - The negative covenants therein are not at all unusual in such cases. There is nothing to indicate that they were introduced to avoid tax.The submission that there was no consideration for the negative covenants is therefore rejected - HC
Capital receipt not chargeable to tax - bifurcation of income - The negative covenants therein are not at all unusual in such cases. There is nothing to indicate that they were introduced to avoid tax.The submission that there was no consideration for the negative covenants is therefore rejected - HC
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