Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.
Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.
Note: It is a system-generated summary and is for quick reference only.