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 pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.
Disallowance of pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.
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