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...
Tds U/S 195 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT
Tds U/S 195 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT
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