Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction
TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction
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