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...
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
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