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...
Electronic filing delay in Form 10B may constitute genuine hardship where the audit report and Form 10 were obtained before the return was filed but were not uploaded due to an inadvertent clerical omission connected with the trust's Chartered Accountant. The notes state that the applicable CBDT circular covered the relevant assessment year and that an earlier decision involving the same trust required a non-pedantic approach to technical compliance. The rejection of condonation was quashed, requiring condonation of the delay and enabling consideration of the charitable-income exemption claim.
Electronic filing delay in Form 10B may constitute genuine hardship where the audit report and Form 10 were obtained before the return was filed but were not uploaded due to an inadvertent clerical omission connected with the trust's Chartered Accountant. The notes state that the applicable CBDT circular covered the relevant assessment year and that an earlier decision involving the same trust required a non-pedantic approach to technical compliance. The rejection of condonation was quashed, requiring condonation of the delay and enabling consideration of the charitable-income exemption claim.
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