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...
TDS u/s 194 - Deemed dividend u/s 2(22)(e) - when the loans/advances have been given to a non shareholder, then it is impossible for a payer company to ascertain whether it will attract the provisions of section 2(22)(e) or not - provisions of section 2(22)(e) and 194 do not require the payer assessee company to deduct TDS u/s 194 - AT
TDS u/s 194 - Deemed dividend u/s 2(22)(e) - when the loans/advances have been given to a non shareholder, then it is impossible for a payer company to ascertain whether it will attract the provisions of section 2(22)(e) or not - provisions of section 2(22)(e) and 194 do not require the payer assessee company to deduct TDS u/s 194 - AT
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