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...
Disallowance u/s 14A - precondition of applicability of Sec 14A - interest paid on loan / borrowed funds - The tribunal held that the precondition of applicability of Section 14A had not been fulfilled in the present case and that there was no discussion as to how interest payment had been incurred in relation to some exempted income. Therefore, the disallowance made under Section 14A was directed to be deleted. - AT
Disallowance u/s 14A - precondition of applicability of Sec 14A - interest paid on loan / borrowed funds - The tribunal held that the precondition of applicability of Section 14A had not been fulfilled in the present case and that there was no discussion as to how interest payment had been incurred in relation to some exempted income. Therefore, the disallowance made under Section 14A was directed to be deleted. - AT
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