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...
Classification of services - Business Auxiliary Services or not - Sales Promotion Agency - Although there is only one wholesale buyer, APBCL, their orders depend on the orders which the retailers place on the depots of APBCL. The appellant was specifically required to ensure that the retailers place maximum quantities of the client’s products on APBCL depots. Thus, the services rendered by the appellant are in the nature of promotion and marketing of the clients’ products - AT
Classification of services - Business Auxiliary Services or not - Sales Promotion Agency - Although there is only one wholesale buyer, APBCL, their orders depend on the orders which the retailers place on the depots of APBCL. The appellant was specifically required to ensure that the retailers place maximum quantities of the client’s products on APBCL depots. Thus, the services rendered by the appellant are in the nature of promotion and marketing of the clients’ products - AT
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