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...
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
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