Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.
Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.
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