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...
Income recognised on completion of consultancy services and invoicing should not be taxed again merely because the related tax credit appears in Form 26AS in a later year; the reported addition was deleted after reconciliation of the invoices. Property-transfer charges and commission, although not deductible as business expenditure, were to be considered in computing capital gains because they related to the sale. Professional fees claimed for arranging working-capital funding required proof of their business utility; in the absence of adequate substantiation, only part of the claim was allowed and half was disallowed. The appeal was partly allowed.
Income recognised on completion of consultancy services and invoicing should not be taxed again merely because the related tax credit appears in Form 26AS in a later year; the reported addition was deleted after reconciliation of the invoices. Property-transfer charges and commission, although not deductible as business expenditure, were to be considered in computing capital gains because they related to the sale. Professional fees claimed for arranging working-capital funding required proof of their business utility; in the absence of adequate substantiation, only part of the claim was allowed and half was disallowed. The appeal was partly allowed.
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