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...
The ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication. Regarding the Transfer Pricing adjustment, the ITAT admitted additional evidence filed by the assessee and directed the TPO to determine the Most Appropriate Method for computing Arm's Length Price after considering the new evidence. Concerning the disallowance of business promotion expenses, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication after the assessee agreed to file evidence.
The ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication. Regarding the Transfer Pricing adjustment, the ITAT admitted additional evidence filed by the assessee and directed the TPO to determine the Most Appropriate Method for computing Arm's Length Price after considering the new evidence. Concerning the disallowance of business promotion expenses, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication after the assessee agreed to file evidence.
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