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...
Advance Ruling application maintainable for recipient liable to pay tax on reverse charge basis, despite definition of 'advance ruling' - Section 95 to be interpreted contextually - Fiction u/s 9(3) brings recipient within ambit of Chapter XVII for seeking Advance Ruling - Application erroneously rejected at threshold u/s 98(2) - No appeal lies against rejection u/s 98(2) - Matter remitted to AAR to decide application afresh u/s 98(4) - Impugned order set aside - Petition allowed by way of remand.
Advance Ruling application maintainable for recipient liable to pay tax on reverse charge basis, despite definition of 'advance ruling' - Section 95 to be interpreted contextually - Fiction u/s 9(3) brings recipient within ambit of Chapter XVII for seeking Advance Ruling - Application erroneously rejected at threshold u/s 98(2) - No appeal lies against rejection u/s 98(2) - Matter remitted to AAR to decide application afresh u/s 98(4) - Impugned order set aside - Petition allowed by way of remand.
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