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...
Limitation for rectification was held to run from the operative reassessment order, because settlement under the DTVSV Scheme does not extinguish the reassessment order itself; the rectification application was therefore within time. The Tribunal also held that a pure legal claim based on facts already on record can be raised in rectification and appellate proceedings even without a revised return, and the Goetze restriction does not bind appellate authorities. Applying the purpose test, the fertilizer subsidy under the Nutrient Based Subsidy Policy was treated as a capital receipt, and as a non-taxable capital receipt it was excluded from book profit under section 115JB. Relief was allowed for one year and upheld for the other.
Limitation for rectification was held to run from the operative reassessment order, because settlement under the DTVSV Scheme does not extinguish the reassessment order itself; the rectification application was therefore within time. The Tribunal also held that a pure legal claim based on facts already on record can be raised in rectification and appellate proceedings even without a revised return, and the Goetze restriction does not bind appellate authorities. Applying the purpose test, the fertilizer subsidy under the Nutrient Based Subsidy Policy was treated as a capital receipt, and as a non-taxable capital receipt it was excluded from book profit under section 115JB. Relief was allowed for one year and upheld for the other.
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