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...
Bad-debt deduction after 1 April 1989 requires write-off in the accounts and satisfaction of the condition that the debt was considered in computing income; actual irrecoverability need not be established. The notes state that revision under section 263 is impermissible where the assessment record shows that the Assessing Officer examined the claim and supporting evidence. They also explain that reconciled contract receipts cannot be treated as understated merely because bank credits include mobilisation, material or other non-revenue advances. A reasoned assessment order is not required where documentary replies have been examined and accepted.
Bad-debt deduction after 1 April 1989 requires write-off in the accounts and satisfaction of the condition that the debt was considered in computing income; actual irrecoverability need not be established. The notes state that revision under section 263 is impermissible where the assessment record shows that the Assessing Officer examined the claim and supporting evidence. They also explain that reconciled contract receipts cannot be treated as understated merely because bank credits include mobilisation, material or other non-revenue advances. A reasoned assessment order is not required where documentary replies have been examined and accepted.
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