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...
Withholding certificates u/s 197 issued at lower rate tax - Respondents are required to pass an order u/s 197 either rejecting the application for such certificate or allowing such application resulting in issuance of certificates which may be at rates higher than nil rate sought for by the assessee, such an order must be supported by reasons. - In the instant case, we do not know the reasons for not granting nil rate certificates to the petitioner u/s 197 - The contemporaneous order required to be passed under section 197 of the Act is also not available - Matter restored back - HC
Withholding certificates u/s 197 issued at lower rate tax - Respondents are required to pass an order u/s 197 either rejecting the application for such certificate or allowing such application resulting in issuance of certificates which may be at rates higher than nil rate sought for by the assessee, such an order must be supported by reasons. - In the instant case, we do not know the reasons for not granting nil rate certificates to the petitioner u/s 197 - The contemporaneous order required to be passed under section 197 of the Act is also not available - Matter restored back - HC
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