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...
TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of the assessee - Net margins of the assessee as well as comparable companies are computed under TNM method on the basis of book results without making any adjustment as prescribed in sec.28 to 44 of the Act (both in the hands of the assessee as well as in the hands of comparable companies.) Hence these contentions of the assessee are untenable and hence liable to be rejected. - AT
TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of the assessee - Net margins of the assessee as well as comparable companies are computed under TNM method on the basis of book results without making any adjustment as prescribed in sec.28 to 44 of the Act (both in the hands of the assessee as well as in the hands of comparable companies.) Hence these contentions of the assessee are untenable and hence liable to be rejected. - AT
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