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...
Addition of deemed dividend under Section 2(22)(e) - quantum of accumulated profits - inclusion of share premium - The share premium account cannot partake the nature of commercial profit and, therefore, it cannot be called as accumulated profits - AT
Addition of deemed dividend under Section 2(22)(e) - quantum of accumulated profits - inclusion of share premium - The share premium account cannot partake the nature of commercial profit and, therefore, it cannot be called as accumulated profits - AT
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