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...
TEC does not have a permanent establishment in India in terms of Article 5(2)(k) of the India-USA Tax Treaty. The assessee did not have an obligation to withhold taxes at source on payments made to TEC, USA. Assessee's appeal allowed.
TEC does not have a permanent establishment in India in terms of Article 5(2)(k) of the India-USA Tax Treaty. The assessee did not have an obligation to withhold taxes at source on payments made to TEC, USA. Assessee's appeal allowed.
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