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...
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Form No. 26A compliance may prevent disallowance of interest expenditure for non-deduction of tax where payees have reported the income, paid tax and supplied complete accountant's certificates; portal-related delay not attributable to the payer does not invalidate that compliance. The notes also state that interest-free business advances do not generate taxable notional interest without a contractual right, actual accrual or receipt, or statutory basis. An ICDS amount entered in the wrong return column should be corrected rather than added twice. A substantiated creditor balance cannot be treated as unexplained solely because the supplier does not answer a notice, and section 68 does not cover an opening balance. Remaining business loss requires verification for lawful carry-forward.
Form No. 26A compliance may prevent disallowance of interest expenditure for non-deduction of tax where payees have reported the income, paid tax and supplied complete accountant's certificates; portal-related delay not attributable to the payer does not invalidate that compliance. The notes also state that interest-free business advances do not generate taxable notional interest without a contractual right, actual accrual or receipt, or statutory basis. An ICDS amount entered in the wrong return column should be corrected rather than added twice. A substantiated creditor balance cannot be treated as unexplained solely because the supplier does not answer a notice, and section 68 does not cover an opening balance. Remaining business loss requires verification for lawful carry-forward.
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