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...
Disallowance of interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s contract agreement with the creditor party and therefore, the CIT(A) has held that the same is not exigible to ‘actual payment’ contemplated u/s.43B of the Act. - No additions - AT
Disallowance of interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s contract agreement with the creditor party and therefore, the CIT(A) has held that the same is not exigible to ‘actual payment’ contemplated u/s.43B of the Act. - No additions - AT
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