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...
Charging interest u/s. 234B(3) / (4) - The section 234B(4) states that if there is any increase or decrease in the income, correspondingly interest shall be increased or reduced accordingly. In the instant case, since reassessment u/s 147 of the Act was completed and in the reassessment the assessed income being higher, the interest is to be calculated as per section 234B(3) of the Income-tax Act, instead of section 234B(4) of the Income-tax Act. - AT
Charging interest u/s. 234B(3) / (4) - The section 234B(4) states that if there is any increase or decrease in the income, correspondingly interest shall be increased or reduced accordingly. In the instant case, since reassessment u/s 147 of the Act was completed and in the reassessment the assessed income being higher, the interest is to be calculated as per section 234B(3) of the Income-tax Act, instead of section 234B(4) of the Income-tax Act. - AT
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