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...
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Additions - under pricing to sister concern - This action of the A.O. is unjustified. Hence, the addition on account of underpricing was not warranted. The assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year. Moreover, there was no finding by the lower authorities that sister concerns benefited in any manner.
Additions - under pricing to sister concern - This action of the A.O. is unjustified. Hence, the addition on account of underpricing was not warranted. The assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year. Moreover, there was no finding by the lower authorities that sister concerns benefited in any manner.
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