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...
Power of Tribunal for enhancement - The AO at no point of time, disputed the date on which the business of the assessee was set up but disputed allowability of certain expenses on ground that assessee not commenced its commercial activity - Tribunal has no jurisdiction in venturing into an issue which was never an issue before the AO and cannot take away the benefit given to the assessee by the AO
Power of Tribunal for enhancement - The AO at no point of time, disputed the date on which the business of the assessee was set up but disputed allowability of certain expenses on ground that assessee not commenced its commercial activity - Tribunal has no jurisdiction in venturing into an issue which was never an issue before the AO and cannot take away the benefit given to the assessee by the AO
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