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...
Deduction for expenditure allegedly disallowed in an earlier year for tax-deduction-at-source default requires evidence that the earlier disallowance was made under the relevant provision; a revised computation cannot support the balance annuity deduction without that factual foundation. A return-processing adjustment must be challenged through the separate statutory appeal already filed where no fresh addition is made in the assessment order. Exemption for an entity under section 10(46) requires the prescribed notification; a pending writ petition, absent a stay or specific direction, does not suspend proceedings or establish exemption eligibility. The deduction and exemption claims were rejected, and all appeals were dismissed.
Deduction for expenditure allegedly disallowed in an earlier year for tax-deduction-at-source default requires evidence that the earlier disallowance was made under the relevant provision; a revised computation cannot support the balance annuity deduction without that factual foundation. A return-processing adjustment must be challenged through the separate statutory appeal already filed where no fresh addition is made in the assessment order. Exemption for an entity under section 10(46) requires the prescribed notification; a pending writ petition, absent a stay or specific direction, does not suspend proceedings or establish exemption eligibility. The deduction and exemption claims were rejected, and all appeals were dismissed.
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