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...
Reassessment of an approved educational trust is unwarranted where, even after proposed disallowances, income applied to its objects remains above the 85% exemption threshold and no taxable income escapes assessment. The proviso to section 10(23C)(vi) permits accumulation of up to 15% of income, while section 152(2) permits reassessment proceedings to be dropped if the alleged escaped income does not reduce the assessed tax liability. Reopening and consequential reassessment were quashed. Revisionary power under section 264 may also modify, revoke or set aside an assessment made contrary to an interim court order, provided the resulting order is not prejudicial to the assessee; administrative system limitations do not excuse failure to remedy the breach.
Reassessment of an approved educational trust is unwarranted where, even after proposed disallowances, income applied to its objects remains above the 85% exemption threshold and no taxable income escapes assessment. The proviso to section 10(23C)(vi) permits accumulation of up to 15% of income, while section 152(2) permits reassessment proceedings to be dropped if the alleged escaped income does not reduce the assessed tax liability. Reopening and consequential reassessment were quashed. Revisionary power under section 264 may also modify, revoke or set aside an assessment made contrary to an interim court order, provided the resulting order is not prejudicial to the assessee; administrative system limitations do not excuse failure to remedy the breach.
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