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...
Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.
Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.
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