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...
Disallowance of commission paid to foreign agents - The Tribunal upheld the disallowance of commission expenses to both domestic and non-resident companies due to the lack of evidence of services provided and non-compliance with TDS requirements. Similarly, the disallowance of legal and professional charges was upheld as the services originated from India. Additionally, the Tribunal upheld the disallowance of interest expenses, noting the diversion of interest-bearing funds for non-business purposes
Disallowance of commission paid to foreign agents - The Tribunal upheld the disallowance of commission expenses to both domestic and non-resident companies due to the lack of evidence of services provided and non-compliance with TDS requirements. Similarly, the disallowance of legal and professional charges was upheld as the services originated from India. Additionally, the Tribunal upheld the disallowance of interest expenses, noting the diversion of interest-bearing funds for non-business purposes
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