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...
Minimum Alternate Tax under section 115JB does not apply to a statutory body constituted under a Central enactment that is not incorporated under the Companies Act, despite being assessable as a company under the Income-tax Act. Applying the principle that the legal fiction in section 115JB cannot extend to such entities, the High Court found the provision inapplicable. Consequently, the issue of disallowance under section 14A in computing book profit did not survive, as it depended on section 115JB applying. No substantial question of law arose, and the Revenue's appeals were dismissed.
Minimum Alternate Tax under section 115JB does not apply to a statutory body constituted under a Central enactment that is not incorporated under the Companies Act, despite being assessable as a company under the Income-tax Act. Applying the principle that the legal fiction in section 115JB cannot extend to such entities, the High Court found the provision inapplicable. Consequently, the issue of disallowance under section 14A in computing book profit did not survive, as it depended on section 115JB applying. No substantial question of law arose, and the Revenue's appeals were dismissed.
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