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...
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
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