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...
Income accrued in India - Having considered the facts in totality and discussed in preceding paras, we do not see any commercial or economic rationale or ease of doing business in incorporating the applicant in Mauritius and interposing it in the JV. - the applicant is not entitled to benefit under Article 13(4) of Indo-Mauritius DTAA in regard to gains arising from the transaction of sale of shares. - AAR
Income accrued in India - Having considered the facts in totality and discussed in preceding paras, we do not see any commercial or economic rationale or ease of doing business in incorporating the applicant in Mauritius and interposing it in the JV. - the applicant is not entitled to benefit under Article 13(4) of Indo-Mauritius DTAA in regard to gains arising from the transaction of sale of shares. - AAR
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
