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...
Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions made by AO deleted - AO directed to attribute 1% of the receipts from offshore supply of equipment as profit of the PE and accordingly compute the income of the assessee. - AT
Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions made by AO deleted - AO directed to attribute 1% of the receipts from offshore supply of equipment as profit of the PE and accordingly compute the income of the assessee. - AT
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