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...
Income accruing or arising in India - dividend on IDR - The Tribunal, in case Morgan Stanley Mauritius Co Ltd. [2021 (5) TMI 968 - ITAT MUMBAI], after examining the transaction concluded that the taxability of IDR dividends fail in the light of India – Mauritius DTAA –Article 22. - AT
Income accruing or arising in India - dividend on IDR - The Tribunal, in case Morgan Stanley Mauritius Co Ltd. [2021 (5) TMI 968 - ITAT MUMBAI], after examining the transaction concluded that the taxability of IDR dividends fail in the light of India – Mauritius DTAA –Article 22. - AT
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