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...
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Disallowance of professional fee paid - genuineness of expenses - Even a layman will not convince that after paying crores of rupees over the period to consultant assessee is not in possession of any document in the form of report/advice/road map/blueprint about the project, company, HR matters, Legal matters, financial matters, Engineering Services etc. Assessee’s counsel vehemently argued the matter but despite of bench’s specific reference about the reports of deliverables his reply was not satisfactory. - AT
Disallowance of professional fee paid - genuineness of expenses - Even a layman will not convince that after paying crores of rupees over the period to consultant assessee is not in possession of any document in the form of report/advice/road map/blueprint about the project, company, HR matters, Legal matters, financial matters, Engineering Services etc. Assessee’s counsel vehemently argued the matter but despite of bench’s specific reference about the reports of deliverables his reply was not satisfactory. - AT
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