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...
TP upward adjustment on account of interest free loan to AE - The interest cost compared to the amount of gross import of material and export generated by the taxpayer is negligible. - No adjustment under transfer pricing provisions is required for the interest-free loans and advances to associated enterprises. - The assessee's appeal is allowed. - AT
TP upward adjustment on account of interest free loan to AE - The interest cost compared to the amount of gross import of material and export generated by the taxpayer is negligible. - No adjustment under transfer pricing provisions is required for the interest-free loans and advances to associated enterprises. - The assessee's appeal is allowed. - AT
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