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...
Notional rental income was deleted because the earlier rent memorandum had been superseded by an operative agreement, independently confirmed by the tenant and supported by invoices, banking records and tax statements. Booking advances did not constitute ceased or bogus liabilities merely because they remained outstanding; sale and transfer documentation supported their continuity. An opening loan balance could not be treated as unexplained cash credit because no credit arose during the relevant year. A debt written off in the accounts qualified for deduction without proof of actual irrecoverability. Supported repairs and routine business expenses were allowed, but interest on tax deducted at source remained disallowed. Penalty was deleted while the assessment's jurisdiction remained under challenge, subject to lawful reinitiation after the writ petition's disposal.
Notional rental income was deleted because the earlier rent memorandum had been superseded by an operative agreement, independently confirmed by the tenant and supported by invoices, banking records and tax statements. Booking advances did not constitute ceased or bogus liabilities merely because they remained outstanding; sale and transfer documentation supported their continuity. An opening loan balance could not be treated as unexplained cash credit because no credit arose during the relevant year. A debt written off in the accounts qualified for deduction without proof of actual irrecoverability. Supported repairs and routine business expenses were allowed, but interest on tax deducted at source remained disallowed. Penalty was deleted while the assessment's jurisdiction remained under challenge, subject to lawful reinitiation after the writ petition's disposal.
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