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...
Applicability of section 33AB(7) - The provisions of section 33AB (7) uses the expression ‘being utilised’ - assessee had paid substantial portion of the proforma invoice value as advance before 31.3.2012 and had included the same in the utilization statement - action of the revenue in bringing to tax the deemed income in terms of section 33AB(7) deserves to be deleted - AT
Applicability of section 33AB(7) - The provisions of section 33AB (7) uses the expression ‘being utilised’ - assessee had paid substantial portion of the proforma invoice value as advance before 31.3.2012 and had included the same in the utilization statement - action of the revenue in bringing to tax the deemed income in terms of section 33AB(7) deserves to be deleted - AT
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