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...
Educational trust exemption was sustained despite allegations that development fee collections and surplus indicated capitation fee or profit motive, because the prior year's finding that the assessee was charitable and engaged in education had already been affirmed, and no fresh distinguishing material or proved violation of the capitation fee law was shown. Depreciation on trust assets remained allowable for A.Y. 2014-15, since section 11(6) operates prospectively from A.Y. 2015-16 and depreciation is part of real income computation; the disallowance failed. Capital gains exemption under section 11(1A) was also allowed on compulsory acquisition proceeds, as reinvestment in new capital assets is tested on substance and does not require strict fund-to-fund tracing, with proportionate relief available.
Educational trust exemption was sustained despite allegations that development fee collections and surplus indicated capitation fee or profit motive, because the prior year's finding that the assessee was charitable and engaged in education had already been affirmed, and no fresh distinguishing material or proved violation of the capitation fee law was shown. Depreciation on trust assets remained allowable for A.Y. 2014-15, since section 11(6) operates prospectively from A.Y. 2015-16 and depreciation is part of real income computation; the disallowance failed. Capital gains exemption under section 11(1A) was also allowed on compulsory acquisition proceeds, as reinvestment in new capital assets is tested on substance and does not require strict fund-to-fund tracing, with proportionate relief available.
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