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...
Addition u/s 40(a)(ia) - Non deduction of TDS on freight expense - non-residents ship owners/charters - the relation between the assessee and the agent was that of a principal and agent. The ITAT in that matter had held that there was an obligation to deduct the tax at source from the payment of transfer charges and other charges were concerned, which had been complied with by the agent. - Order of CIT(A) and ITAT deleting the additions sustained - HC
Addition u/s 40(a)(ia) - Non deduction of TDS on freight expense - non-residents ship owners/charters - the relation between the assessee and the agent was that of a principal and agent. The ITAT in that matter had held that there was an obligation to deduct the tax at source from the payment of transfer charges and other charges were concerned, which had been complied with by the agent. - Order of CIT(A) and ITAT deleting the additions sustained - HC
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