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...
The High Court addressed the rejection of a blanket unconditional stay on tax and interest demands by the Tribunal. The Tribunal granted a conditional stay, requiring the petitioner to pay Rs. 230 crores, provide a corporate guarantee exceeding Rs. 900 crores, and cooperate in appeal disposal. The Court held that the recovery was not protective and upheld the Tribunal's order, noting prior years' compliance. The Court modified the corporate guarantee condition to the ultimate parent company, Vodafone International Holdings BV. The Court affirmed the Tribunal's order, except for the modified condition.
The High Court addressed the rejection of a blanket unconditional stay on tax and interest demands by the Tribunal. The Tribunal granted a conditional stay, requiring the petitioner to pay Rs. 230 crores, provide a corporate guarantee exceeding Rs. 900 crores, and cooperate in appeal disposal. The Court held that the recovery was not protective and upheld the Tribunal's order, noting prior years' compliance. The Court modified the corporate guarantee condition to the ultimate parent company, Vodafone International Holdings BV. The Court affirmed the Tribunal's order, except for the modified condition.
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