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 - now when the assessee has been held as an agent of independent status, and the income of M/s Arc Line, Mauritius in the absence of any PE in India had been held as not taxable in India, therefore, there remains no basis for taxing the income of M/s Arc Line, Mauritius from its shipping activities under Sec. 44B of the Act in the hands of the assessee by treating it as a representative assessee of the aforesaid company. - AT
Income accrued in India - now when the assessee has been held as an agent of independent status, and the income of M/s Arc Line, Mauritius in the absence of any PE in India had been held as not taxable in India, therefore, there remains no basis for taxing the income of M/s Arc Line, Mauritius from its shipping activities under Sec. 44B of the Act in the hands of the assessee by treating it as a representative assessee of the aforesaid company. - AT
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