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...
Assessee lent money from borrowed funds, charging higher interest rate than paid, later lending from own funds. Total interest paid eligible for deduction, though assessee suo moto disallowed part. No further disallowance warranted by authorities. Maturity proceeds from keyman insurance policy exempt u/s 10(10D), without bifurcation, following precedent. Authorities erred in denying exemption. Decisions favored assessee on both issues.
Assessee lent money from borrowed funds, charging higher interest rate than paid, later lending from own funds. Total interest paid eligible for deduction, though assessee suo moto disallowed part. No further disallowance warranted by authorities. Maturity proceeds from keyman insurance policy exempt u/s 10(10D), without bifurcation, following precedent. Authorities erred in denying exemption. Decisions favored assessee on both issues.
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