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...
Insurance compensation for fire damage to stock and business interiors should not be separately added to business income where it has already been adjusted against the loss and only the net loss is debited in the profit and loss account; a further addition would duplicate taxation while ignoring the corresponding loss. The discussion distinguishes such compensation from compensation for loss of a capital asset and therefore from capital-gains treatment. It also states that an appellate authority should not sustain an addition on a wholly different basis without addressing the assessment's original foundation. Deletion of the related quantum addition removes the basis for a concealment penalty.
Insurance compensation for fire damage to stock and business interiors should not be separately added to business income where it has already been adjusted against the loss and only the net loss is debited in the profit and loss account; a further addition would duplicate taxation while ignoring the corresponding loss. The discussion distinguishes such compensation from compensation for loss of a capital asset and therefore from capital-gains treatment. It also states that an appellate authority should not sustain an addition on a wholly different basis without addressing the assessment's original foundation. Deletion of the related quantum addition removes the basis for a concealment penalty.
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