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...
Partial denial of exemption for benefit to specified persons was confined to the income said to have been diverted; the broader exemption under sections 11 and 12 was not forfeited in full, and the 15 per cent amount treated as deemed application under section 11 was deleted. A payment to a related concern was not hit by the specified concern rule because the trustee's voting power was below the 20 per cent threshold, and a procedural error in Form 10B did not defeat the exemption claim. Capital expenditure was also allowed as application of income on an accrual basis, with supporting invoices, disclosure in the balance sheet, and replies to notices sufficient on the facts.
Partial denial of exemption for benefit to specified persons was confined to the income said to have been diverted; the broader exemption under sections 11 and 12 was not forfeited in full, and the 15 per cent amount treated as deemed application under section 11 was deleted. A payment to a related concern was not hit by the specified concern rule because the trustee's voting power was below the 20 per cent threshold, and a procedural error in Form 10B did not defeat the exemption claim. Capital expenditure was also allowed as application of income on an accrual basis, with supporting invoices, disclosure in the balance sheet, and replies to notices sufficient on the facts.
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