Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Commercial Training or Coaching Services - appellant is a PSU mainly engaged in the activity of ship building and repair works - The lower authority seemed to have lost sight of the factual position that the subject courses have been approved by the Director General of Shipping, Ministry of Surface Transport, Govt. of India, in consonance with the provisions of the Merchant Shipping Act, 1958, a fact which was always available before them - There cannot be any iota of doubt to hold that the courses assumes to be of statutory nature and hence, qualifies as being “recognised under the law”
Commercial Training or Coaching Services - appellant is a PSU mainly engaged in the activity of ship building and repair works - The lower authority seemed to have lost sight of the factual position that the subject courses have been approved by the Director General of Shipping, Ministry of Surface Transport, Govt. of India, in consonance with the provisions of the Merchant Shipping Act, 1958, a fact which was always available before them - There cannot be any iota of doubt to hold that the courses assumes to be of statutory nature and hence, qualifies as being “recognised under the law”
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