17 July, 2015
Corporate guarantees have often been examined for transfer pricing adjustment. While there are number of judgements on how to determine the ALP and that bank rates are not to be applied, whether the transaction is an international transaction is always intriguing.
ITAT, Hyderabad in its decision in Four Soft P Ltd v. DCIT...
Affiliates of Multi National Enterprises (‘MNEs’), in the recent past, are moving more towards functioning independently from their parent, operational and financial. The freedom given in managing their own affairs in growing economies like India, has helped the affiliates to grow faster in the local markets. However, ...
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