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...
Capital gain arising on transfer of land - STCG arising out of the transfer of non-agricultural land - real owner - The appellant asserts that the land was purchased on behalf of the company, as evidenced by a development agreement executed between the appellant and the company. However, the Tribunal finds no explicit indication in the documents that the appellant was authorized by the company to purchase the land on its behalf. The absence of a memorandum of understanding or any explicit authorization leads the Tribunal to conclude that the land was purchased by the appellant individually, not on behalf of the company.
Capital gain arising on transfer of land - STCG arising out of the transfer of non-agricultural land - real owner - The appellant asserts that the land was purchased on behalf of the company, as evidenced by a development agreement executed between the appellant and the company. However, the Tribunal finds no explicit indication in the documents that the appellant was authorized by the company to purchase the land on its behalf. The absence of a memorandum of understanding or any explicit authorization leads the Tribunal to conclude that the land was purchased by the appellant individually, not on behalf of the company.
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