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...
Advance rulings under Section 95(a) are prospective; where all contractual acts, possession and payment were completed before filing, the transaction is not a supply "being undertaken or proposed" and therefore falls outside the AAR's permissible scope. The authority found that the assignment of leasehold rights and related charges were fully executed before the application, so questions on taxability of land development charges and eligibility of input tax credit could not be determined by advance ruling. Consequence: the application was held not maintainable and the AAR declined to decide the substantive tax issues.
Advance rulings under Section 95(a) are prospective; where all contractual acts, possession and payment were completed before filing, the transaction is not a supply "being undertaken or proposed" and therefore falls outside the AAR's permissible scope. The authority found that the assignment of leasehold rights and related charges were fully executed before the application, so questions on taxability of land development charges and eligibility of input tax credit could not be determined by advance ruling. Consequence: the application was held not maintainable and the AAR declined to decide the substantive tax issues.
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