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...
Section 87A, as applicable for the relevant assessment year, did not exclude tax on short-term capital gains taxable under section 111A. Although section 112A expressly limits the rebate for specified long-term capital gains, no equivalent restriction applied to section 111A income; the special tax rate governs tax computation but does not curtail the independent rebate absent express legislation. A later amendment restricting the rebate to tax computed under section 115BAC(1A), effective from Assessment Year 2026-27, cannot deny the benefit for Assessment Year 2024-25 without express retrospective operation. The notes state that rebate was to be granted and tax recomputed accordingly.
Section 87A, as applicable for the relevant assessment year, did not exclude tax on short-term capital gains taxable under section 111A. Although section 112A expressly limits the rebate for specified long-term capital gains, no equivalent restriction applied to section 111A income; the special tax rate governs tax computation but does not curtail the independent rebate absent express legislation. A later amendment restricting the rebate to tax computed under section 115BAC(1A), effective from Assessment Year 2026-27, cannot deny the benefit for Assessment Year 2024-25 without express retrospective operation. The notes state that rebate was to be granted and tax recomputed accordingly.
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