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...
ITAT remanded certain TP issues to the AO/TPO: additional evidence submitted by the assessee must be verified and the TPO shall determine benefit and compute ALP adopting TNMM in accordance with s.92C and Rules 10B/10C, affording the assessee hearing. The TPO exceeded jurisdiction by itemising assets in a slump sale and applying s.50C; the Tribunal directed acceptance of DCF valuation and the Form 3CEA fair value under s.50B. Selection of specified comparables for IPS division was upheld. Reimbursements by the assessee to its AE are cost-to-cost with no separate mark-up. Disallowance of provisions for contract losses was sustained; reversal is partly allowed subject to AO's verification of creation year and linkage to the disallowed provision.
ITAT remanded certain TP issues to the AO/TPO: additional evidence submitted by the assessee must be verified and the TPO shall determine benefit and compute ALP adopting TNMM in accordance with s.92C and Rules 10B/10C, affording the assessee hearing. The TPO exceeded jurisdiction by itemising assets in a slump sale and applying s.50C; the Tribunal directed acceptance of DCF valuation and the Form 3CEA fair value under s.50B. Selection of specified comparables for IPS division was upheld. Reimbursements by the assessee to its AE are cost-to-cost with no separate mark-up. Disallowance of provisions for contract losses was sustained; reversal is partly allowed subject to AO's verification of creation year and linkage to the disallowed provision.
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