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...
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
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