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...
Smuggling - foreign currency - illicit export of currency - beneficial owners - The actual owner of the foreign currency having been identified, the concept of ‘beneficial owner’ does not arise. The Commissioner (Appeals), therefore, was not justified in reversing the finding recorded by the Additional Commissioner that the concept of ‘beneficial owner’ would not arise in the facts and circumstances of the case. - AT
Smuggling - foreign currency - illicit export of currency - beneficial owners - The actual owner of the foreign currency having been identified, the concept of ‘beneficial owner’ does not arise. The Commissioner (Appeals), therefore, was not justified in reversing the finding recorded by the Additional Commissioner that the concept of ‘beneficial owner’ would not arise in the facts and circumstances of the case. - AT
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