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...
Revision u/s 263 - Pr. CIT directed to make addition/disallowance in respect of expenditure incurred towards R&D u/s 35(2AB); Capital R&D expense allocated to Sun Pharmaceuticals Industries and re-characterization of remuneration earned from partnership firm (SPI) as royalty income - similar disallowances were already subject matter of appeals before Tribunal in earlier years in favour of assessee - revision order is not sustainable
Revision u/s 263 - Pr. CIT directed to make addition/disallowance in respect of expenditure incurred towards R&D u/s 35(2AB); Capital R&D expense allocated to Sun Pharmaceuticals Industries and re-characterization of remuneration earned from partnership firm (SPI) as royalty income - similar disallowances were already subject matter of appeals before Tribunal in earlier years in favour of assessee - revision order is not sustainable
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