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...
Derivative option losses claimed through a recognised exchange and registered broker require independent proof of genuineness where investigation material indicates manipulated transactions. Contract notes and banking-channel payments alone were insufficient in light of broker admissions, options acquired shortly before expiry and allowed to lapse, and repeated losses; the taxpayer did not rebut this material, so the loss disallowance was sustained. Jurisdictional objections to reassessment, raised specifically before the Tribunal and requiring factual verification, were admitted but remanded to the appellate authority for detailed adjudication. The appeal was partly allowed for statistical purposes.
Derivative option losses claimed through a recognised exchange and registered broker require independent proof of genuineness where investigation material indicates manipulated transactions. Contract notes and banking-channel payments alone were insufficient in light of broker admissions, options acquired shortly before expiry and allowed to lapse, and repeated losses; the taxpayer did not rebut this material, so the loss disallowance was sustained. Jurisdictional objections to reassessment, raised specifically before the Tribunal and requiring factual verification, were admitted but remanded to the appellate authority for detailed adjudication. The appeal was partly allowed for statistical purposes.
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