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...
TDS u/s 195 - assessee has already deducted tax under section 192 of the Act in respect of salary cost of expatriate employees - where profit attribution to a PE is based on a notional calculation rather than actual payments (e.g., markup on salaries of expatriate employees), the assessee cannot be expected to deduct tax on such notional income, especially when tax has already been deducted on the actual payments under different sections of the Income-tax Act. - AT
TDS u/s 195 - assessee has already deducted tax under section 192 of the Act in respect of salary cost of expatriate employees - where profit attribution to a PE is based on a notional calculation rather than actual payments (e.g., markup on salaries of expatriate employees), the assessee cannot be expected to deduct tax on such notional income, especially when tax has already been deducted on the actual payments under different sections of the Income-tax Act. - AT
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