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 - Comparable selection - determination of arm’s length prices (ALP) - The High Court observed that the dissimilarity in products sold and their respective turnovers could significantly impact the profitability of an entity. Despite acknowledging significant differences and accepting the appellant's arguments, the ITAT failed to entirely exclude Modicare. The Court considered this a vital infirmity and directed the ITAT to re-examine the appropriateness of including Modicare and the functional difference in marketing strategy between the entities.
TP Adjustment - Comparable selection - determination of arm’s length prices (ALP) - The High Court observed that the dissimilarity in products sold and their respective turnovers could significantly impact the profitability of an entity. Despite acknowledging significant differences and accepting the appellant's arguments, the ITAT failed to entirely exclude Modicare. The Court considered this a vital infirmity and directed the ITAT to re-examine the appropriateness of including Modicare and the functional difference in marketing strategy between the entities.
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