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...
Addition on commission paid to the Managing Director of the assessee company, u/s 36(1)(ii)- The directors are not only shareholders of the company. Therefore, it cannot be said that if the commission was not paid, such sum would have been paid to the employees as profit or dividend - the exception provided in section 36(1)(ii) do not apply - AT
Addition on commission paid to the Managing Director of the assessee company, u/s 36(1)(ii)- The directors are not only shareholders of the company. Therefore, it cannot be said that if the commission was not paid, such sum would have been paid to the employees as profit or dividend - the exception provided in section 36(1)(ii) do not apply - AT
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