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...
Pre-Deposit - Adjustment of various deposits made by entities during the course of investigation - The appellant argued that since they were associated with these entities and deposits were made with No Objection Certificates, these amounts should be adjusted for the pre-deposit requirement. However, the High court upheld the decision of the CESTAT, emphasizing that Section 129E places the responsibility of pre-deposit solely on the appellant, and deposits made by other entities cannot be considered for this purpose. The court's decision was based on the clear language of the provision, and it found no reason to interfere with the CESTAT's order. Thus, the appeal was dismissed.
Pre-Deposit - Adjustment of various deposits made by entities during the course of investigation - The appellant argued that since they were associated with these entities and deposits were made with No Objection Certificates, these amounts should be adjusted for the pre-deposit requirement. However, the High court upheld the decision of the CESTAT, emphasizing that Section 129E places the responsibility of pre-deposit solely on the appellant, and deposits made by other entities cannot be considered for this purpose. The court's decision was based on the clear language of the provision, and it found no reason to interfere with the CESTAT's order. Thus, the appeal was dismissed.
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