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...
Taxability of capital gains - denial of adjustments to full value of sale consideration towards amount lying in Escrow account while determining the LTCG - ITAT accepted the revised computation of capital gains, excluding the amount retained in the escrow account, which was neither received nor expected to be received by the assessee due to subsequent events indicating significant liabilities against the escrow. - As conceded on behalf of the assessee, the amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual.
Taxability of capital gains - denial of adjustments to full value of sale consideration towards amount lying in Escrow account while determining the LTCG - ITAT accepted the revised computation of capital gains, excluding the amount retained in the escrow account, which was neither received nor expected to be received by the assessee due to subsequent events indicating significant liabilities against the escrow. - As conceded on behalf of the assessee, the amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual.
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