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...
Disallowance of R & D units purchased as per Technical License Agreement - when the assessee has purchased a product in order to carry out improvements in its technology for future development and its sales thereafter, then such purchases cannot be said to be payment of royalty - the payment was not for use or use of any technology but for purchase of equipment for R&D purpose - no disallowance
Disallowance of R & D units purchased as per Technical License Agreement - when the assessee has purchased a product in order to carry out improvements in its technology for future development and its sales thereafter, then such purchases cannot be said to be payment of royalty - the payment was not for use or use of any technology but for purchase of equipment for R&D purpose - no disallowance
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