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...
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Note: It is a system-generated summary and is for quick reference only.