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...
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
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