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...
Revision u/s 263 - disallowance u/s 40(a)(ia) - CIT has not correctly interpreted the provisions of sec.194C(2) nor consider the law amended in sec.40(a)(ia) held to be applicable retrospectively - CIT also failed to verify and conduct the minimal enquiry about non-deduction of TDS and deposit of TDS before the due date for filing the return of income - Revision order set aside.
Revision u/s 263 - disallowance u/s 40(a)(ia) - CIT has not correctly interpreted the provisions of sec.194C(2) nor consider the law amended in sec.40(a)(ia) held to be applicable retrospectively - CIT also failed to verify and conduct the minimal enquiry about non-deduction of TDS and deposit of TDS before the due date for filing the return of income - Revision order set aside.
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