Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Page of 4805
Press 'Enter' after typing page number.
5321 to 5340 of 96100 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.
Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
