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...
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
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