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...
Disallowance of interest u/s 36(1)(iii) - assessee has a stake in the performance and profit making of wholly owned subsidiaries - it cannot be denied that the advancement of loan is in connection with assessee’s business - the difference in the interest rate between the borrowed funds and loans advanced is only 3.25% and the advanced of loan in connection with its business - no disallowance
Disallowance of interest u/s 36(1)(iii) - assessee has a stake in the performance and profit making of wholly owned subsidiaries - it cannot be denied that the advancement of loan is in connection with assessee’s business - the difference in the interest rate between the borrowed funds and loans advanced is only 3.25% and the advanced of loan in connection with its business - no disallowance
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