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...
Revision u/s 263 - Non deduction of TDS u/s 195 on brokerage pad to non-resident brokers - This fact is admitted by assessee as in the paperbook index it is mentioned that the declaration by the parties of not having any permanent establishment in India along with their tax residency certificates have not been filed before the AO and have been filed only for the first time before ld. Pr. CIT. - Revision proceedings sustained - AT
Revision u/s 263 - Non deduction of TDS u/s 195 on brokerage pad to non-resident brokers - This fact is admitted by assessee as in the paperbook index it is mentioned that the declaration by the parties of not having any permanent establishment in India along with their tax residency certificates have not been filed before the AO and have been filed only for the first time before ld. Pr. CIT. - Revision proceedings sustained - AT
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