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...
Scope of taxability - Manpower recruitment or supply agency service - Having identified some of the ‘work orders’ to contain compensation on ‘man day’ basis, it was incumbent upon the adjudicating authority, in the light of such finding, to segregate those to which, in accordance with the precedent arising from decisions of the Tribunal, coverage under that taxable service would not extend. This, the adjudicating authority has failed to do. - AT
Scope of taxability - Manpower recruitment or supply agency service - Having identified some of the ‘work orders’ to contain compensation on ‘man day’ basis, it was incumbent upon the adjudicating authority, in the light of such finding, to segregate those to which, in accordance with the precedent arising from decisions of the Tribunal, coverage under that taxable service would not extend. This, the adjudicating authority has failed to do. - AT
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