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...
TP adjustment - exclusion and inclusion of comparables - since in respect of each of the comparables, the ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity and also followed earlier decisions concerning assessee - no substantial question of law arises
TP adjustment - exclusion and inclusion of comparables - since in respect of each of the comparables, the ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity and also followed earlier decisions concerning assessee - no substantial question of law arises
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