Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
TP Adjustment - Upward adjustment of guarantee fee charges - BHPL itself has not claimed it as a deduction from any income and guarantee charges accordingly has been offered to taxation. The amount paid as guarantee charges has already suffered disallowance while filling return of income itself. Hence, again addition the same to total income results in double taxation. - AT
TP Adjustment - Upward adjustment of guarantee fee charges - BHPL itself has not claimed it as a deduction from any income and guarantee charges accordingly has been offered to taxation. The amount paid as guarantee charges has already suffered disallowance while filling return of income itself. Hence, again addition the same to total income results in double taxation. - AT
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