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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Rectification u/s 254(2) - receipt from other advertisers towards sale of online ad space in Inida under AdWord Program is chargeable to tax as 'Royalty - issue is highly debatable and two views are possible. It would not be appropriate to exercise powers u/s.254(2) of the Act as the order does not suffer from any mistake apparent on the face of the record.
Rectification u/s 254(2) - receipt from other advertisers towards sale of online ad space in Inida under AdWord Program is chargeable to tax as 'Royalty - issue is highly debatable and two views are possible. It would not be appropriate to exercise powers u/s.254(2) of the Act as the order does not suffer from any mistake apparent on the face of the record.
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