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...
Proportionate allowability of lease premium u/s 37 - it is difficult to appreciate that fact of rent being depressed rent can only be appreciated as such if there is recital about it in the lease rent - substantial amount of money was paid as premium, claimed and shown by assessee to be advance rents and where rents reserved - no hesitation to infer that rents reserved are depressed rents - deduction allowable
Proportionate allowability of lease premium u/s 37 - it is difficult to appreciate that fact of rent being depressed rent can only be appreciated as such if there is recital about it in the lease rent - substantial amount of money was paid as premium, claimed and shown by assessee to be advance rents and where rents reserved - no hesitation to infer that rents reserved are depressed rents - deduction allowable
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