Tag: The Fiscal Daily

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India coal dependence: why energy security still runs through coal

India can expand renewables fast and still need coal for years. The real story is not ideology but grid reliability, storage gaps, industrial costs, and transition design.

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Mutual Agreement Procedure as Strategy: Why Waiting Too Long Blunts Competent Authority Relief

Mutual Agreement Procedure is increasingly central to India's tax-certainty architecture. The real strategic mistake in 2026 may not be using MAP - it may be using it too late.

APA vs Litigation in 2026: When Should Large Taxpayers Stop Fighting?

India’s APA regime has crossed the proof-of-concept stage. For large taxpayers in 2026, the real question is no longer whether a case can be fought, but whether recurring litigation still delivers more value than certainty.

Transfer Pricing True-Ups at Year-End: Commercial Hygiene or Audit Trigger by Design?

Transfer pricing true-ups are not inherently suspect. But in India, a year-end margin correction becomes defensible only when contracts, monitoring, settlement and Rule 10D evidence all point to one coherent pricing policy.

Intra-group services: India’s benefit-test obsession is becoming a tax-certainty problem

India's transfer pricing fights over intra-group services have become too fixated on proving 'benefit' after the fact. A better test would ask what service was actually rendered, why it was needed, and whether it was priced credibly.

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