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...
Impugned award unaffected by fraud or corruption; Arbitral Tribunal considered materials and submissions; no case made out regarding fraud in passing award. Parties contemplated GST implementation in Share Purchase Agreement; incentives payable only to extent tax accrued to State Government. Withdrawal of exemption notification pursuant to statutory mandate under CGST Act; legislature incorporated proviso allowing rescission of tax exemption incentives. Claim of estoppel rejected. Petitioners failed to make out prima facie case for unconditional stay; directed to secure awarded amount - 50% by transfer, 50% by bank guarantee within six weeks.
Impugned award unaffected by fraud or corruption; Arbitral Tribunal considered materials and submissions; no case made out regarding fraud in passing award. Parties contemplated GST implementation in Share Purchase Agreement; incentives payable only to extent tax accrued to State Government. Withdrawal of exemption notification pursuant to statutory mandate under CGST Act; legislature incorporated proviso allowing rescission of tax exemption incentives. Claim of estoppel rejected. Petitioners failed to make out prima facie case for unconditional stay; directed to secure awarded amount - 50% by transfer, 50% by bank guarantee within six weeks.
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