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...
With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping the aim of transfer pricing in ensuring that the tax base of the country is not eroded the action of the TPO in referring to the International Guidance in order to determine the ALP of the international transaction cannot be faulted with unless we repeat the said action is contrary to the Indian Transfer Pricing Legislation which is not so in the facts of the present case - AT
With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping the aim of transfer pricing in ensuring that the tax base of the country is not eroded the action of the TPO in referring to the International Guidance in order to determine the ALP of the international transaction cannot be faulted with unless we repeat the said action is contrary to the Indian Transfer Pricing Legislation which is not so in the facts of the present case - AT
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