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...
Computation of Capital Gains (Loss) - Determining the cost of acquisition u/s 49(2AA) - Tax Residency Certificate (TRC) - In the instant case, since, the assessee had produced the TRC as per the directions of the DRP, we refrain from adjudicating whether TRC is mandatory for determining the cost of acquisition u/s 49(2AA) of the I.T.Act. - The A.O. is directed to examine the TRC and the same if it is found to be in order, the cost of acquisition shall be taken as claimed by the assessee - AT
Computation of Capital Gains (Loss) - Determining the cost of acquisition u/s 49(2AA) - Tax Residency Certificate (TRC) - In the instant case, since, the assessee had produced the TRC as per the directions of the DRP, we refrain from adjudicating whether TRC is mandatory for determining the cost of acquisition u/s 49(2AA) of the I.T.Act. - The A.O. is directed to examine the TRC and the same if it is found to be in order, the cost of acquisition shall be taken as claimed by the assessee - AT
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