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...
Agricultural land retains its agricultural character at transfer where revenue records and receipts establish agricultural use, and the purchaser obtains non-agricultural-use permission only after sale; the resulting gain is not taxable as capital gains. Agricultural receipts recorded in books and supported by undisputed bills are not unexplained income merely because they were omitted from the return. Profit on sale of shares is assessable as capital gains rather than business income where the shareholder had no control over the company's management or business and the contrary treatment rests solely on an alleged controlling interest.
Agricultural land retains its agricultural character at transfer where revenue records and receipts establish agricultural use, and the purchaser obtains non-agricultural-use permission only after sale; the resulting gain is not taxable as capital gains. Agricultural receipts recorded in books and supported by undisputed bills are not unexplained income merely because they were omitted from the return. Profit on sale of shares is assessable as capital gains rather than business income where the shareholder had no control over the company's management or business and the contrary treatment rests solely on an alleged controlling interest.
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