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...
Assessee's expat salary expenses reimbursed to SanDisk India not taxable as FTS. No agency PE of assessee in India through SanDisk India for relevant year as no transaction between them. Revenue failed to establish SanDisk India acted on behalf of assessee to constitute dependent agency PE under tax treaty. No interrelated transaction brought on record between assessee and SanDisk India as associated enterprises for relevant year. No attribution of SanDisk India's profits to assessee permissible. Decided in assessee's favor.
Assessee's expat salary expenses reimbursed to SanDisk India not taxable as FTS. No agency PE of assessee in India through SanDisk India for relevant year as no transaction between them. Revenue failed to establish SanDisk India acted on behalf of assessee to constitute dependent agency PE under tax treaty. No interrelated transaction brought on record between assessee and SanDisk India as associated enterprises for relevant year. No attribution of SanDisk India's profits to assessee permissible. Decided in assessee's favor.
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