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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Rectification of a return could not be used to enhance business income where amounts such as rent, dividend and bank interest had already been disclosed under their proper heads, because the same sums were again added to business income due to a return-filing error. On examining the return, profit and loss account and computation, the Tribunal accepted that income taxable under other heads had to be reduced from business income when computing net profit. The rectification order was based on an incorrect appreciation of the computation, and the impugned addition was deleted.
Rectification of a return could not be used to enhance business income where amounts such as rent, dividend and bank interest had already been disclosed under their proper heads, because the same sums were again added to business income due to a return-filing error. On examining the return, profit and loss account and computation, the Tribunal accepted that income taxable under other heads had to be reduced from business income when computing net profit. The rectification order was based on an incorrect appreciation of the computation, and the impugned addition was deleted.
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