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...
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
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