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...
Income taxable in India - royalty receipts - Distribution of Financial Products - assessee had granted rights to distribute its various financial and related products in the Indian market to DJCIPL on a principal to principal basis and at arm’s length price. - purchase price of Factiva products distributed by DJCIPL is not taxable as ‘royalty’ under India UK DTAA in the hands of the assessee. - AT
Income taxable in India - royalty receipts - Distribution of Financial Products - assessee had granted rights to distribute its various financial and related products in the Indian market to DJCIPL on a principal to principal basis and at arm’s length price. - purchase price of Factiva products distributed by DJCIPL is not taxable as ‘royalty’ under India UK DTAA in the hands of the assessee. - AT
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