Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
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The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The Tribunal rejected the Transfer Pricing Officer's benchmarking based on Indian bank rates since the Associated Enterprise obtained a loan from a Saudi Arabian bank. Considering the consistent approach of coordinate Benches, the Tribunal directed the Assessing Officer to restrict the arm's length price adjustment to 0.5% for the corporate guarantee fees.
The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The Tribunal rejected the Transfer Pricing Officer's benchmarking based on Indian bank rates since the Associated Enterprise obtained a loan from a Saudi Arabian bank. Considering the consistent approach of coordinate Benches, the Tribunal directed the Assessing Officer to restrict the arm's length price adjustment to 0.5% for the corporate guarantee fees.
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