Timely pronouncement of reserved judgments requires defined timelines, transparency measures, and remedial pathways to protect liberty and effective j...
Settlement-price depression requires proof of manipulation, not merely short exposure, late selling, or below-market orders, preserving disclosure pen...
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring benchmarking and such a treatment is bad under law and working capital adjustment would take into account the impact of outstanding receivables and no need to impute any interest on receivables - the interest shall be charged only at 6% p.a. in respect of the receivables outstanding for more than 30 days. - AT
TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring benchmarking and such a treatment is bad under law and working capital adjustment would take into account the impact of outstanding receivables and no need to impute any interest on receivables - the interest shall be charged only at 6% p.a. in respect of the receivables outstanding for more than 30 days. - AT
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