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...
TP Adjustment - bilateral Advance Pricing Agreement (APA) between India and the USA - modified return of income - The ITAT found merit in the assessee's argument regarding the APA between India and the USA, agreeing that the methodology used for the transactions had been agreed upon. It directed the Assessing Officer to consider the modified return of income in light of the APA and decide the issue afresh after affording reasonable opportunity to the assessee. The court allowed this ground for statistical purposes.
TP Adjustment - bilateral Advance Pricing Agreement (APA) between India and the USA - modified return of income - The ITAT found merit in the assessee's argument regarding the APA between India and the USA, agreeing that the methodology used for the transactions had been agreed upon. It directed the Assessing Officer to consider the modified return of income in light of the APA and decide the issue afresh after affording reasonable opportunity to the assessee. The court allowed this ground for statistical purposes.
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