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...
Unsupported estimation of indexed acquisition and construction or improvement costs cannot sustain capital-gains additions where neither the taxpayers' claims nor the Assessing Officer's adopted land and construction rates are supported by evidence. The reported tribunal decision deleted the resulting cost adjustments in all appeals. For section 54F, acquisition of a new residential property within the statutory period preserves the exemption despite non-deposit of interim unutilised gains in the Capital Gains Account Scheme, treating that omission as procedural. Exemption was allowed for investments made within time, but remained unavailable where the residential-property investment itself occurred beyond the prescribed period.
Unsupported estimation of indexed acquisition and construction or improvement costs cannot sustain capital-gains additions where neither the taxpayers' claims nor the Assessing Officer's adopted land and construction rates are supported by evidence. The reported tribunal decision deleted the resulting cost adjustments in all appeals. For section 54F, acquisition of a new residential property within the statutory period preserves the exemption despite non-deposit of interim unutilised gains in the Capital Gains Account Scheme, treating that omission as procedural. Exemption was allowed for investments made within time, but remained unavailable where the residential-property investment itself occurred beyond the prescribed period.
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