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...
Exemption u/s 11 denied - intimation was issued u/s. 143(1) - The Central Processing Center has also taxed the entire gross receipt of the assessee without allowing any expenditure. This cannot be done while processing the return u/s. 143(1) of the Act. This Tribunal is of the considered opinion that Section 143(1) is meant for prima facie adjustment on the basis of material available on record without giving any opportunity to the assessee. Therefore, rejection of the claim of exemption u/s. 143(1) by Central Processing Center is not justified. - AT
Exemption u/s 11 denied - intimation was issued u/s. 143(1) - The Central Processing Center has also taxed the entire gross receipt of the assessee without allowing any expenditure. This cannot be done while processing the return u/s. 143(1) of the Act. This Tribunal is of the considered opinion that Section 143(1) is meant for prima facie adjustment on the basis of material available on record without giving any opportunity to the assessee. Therefore, rejection of the claim of exemption u/s. 143(1) by Central Processing Center is not justified. - AT
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