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...
For charitable income, Explanation 2(ii)(b) to section 11(1) operated as a mechanism distinct from accumulation under section 11(2): the assessee claimed only deemed application in the immediately succeeding year, not long-term accumulation. The Tribunal held that, for A.Y. 2015-16, a written option within the time allowed under section 139(1) was sufficient; the later Form No. 9A requirement could not be applied retrospectively. Disclosure in the return and furnishing of reasons before completion of assessment satisfied the statutory condition, so the disallowance of deemed application and the consequential denial of exemption were unsustainable.
For charitable income, Explanation 2(ii)(b) to section 11(1) operated as a mechanism distinct from accumulation under section 11(2): the assessee claimed only deemed application in the immediately succeeding year, not long-term accumulation. The Tribunal held that, for A.Y. 2015-16, a written option within the time allowed under section 139(1) was sufficient; the later Form No. 9A requirement could not be applied retrospectively. Disclosure in the return and furnishing of reasons before completion of assessment satisfied the statutory condition, so the disallowance of deemed application and the consequential denial of exemption were unsustainable.
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