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...
Sale proceeds of Renewable Energy Certificates received by renewable-energy power generators are treated as capital receipts because the certificates incentivise environmental benefits of renewable generation rather than arise from producing or selling goods or rendering services. They therefore do not constitute business income or profits derived from an eligible power-generation undertaking for deduction purposes. As capital receipts, the proceeds are also excluded from book profit computed for minimum alternate tax purposes under section 115JB. The Revenue's challenge to deletion of the related disallowance and to exclusion from book profit was rejected.
Sale proceeds of Renewable Energy Certificates received by renewable-energy power generators are treated as capital receipts because the certificates incentivise environmental benefits of renewable generation rather than arise from producing or selling goods or rendering services. They therefore do not constitute business income or profits derived from an eligible power-generation undertaking for deduction purposes. As capital receipts, the proceeds are also excluded from book profit computed for minimum alternate tax purposes under section 115JB. The Revenue's challenge to deletion of the related disallowance and to exclusion from book profit was rejected.
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