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...
Power of CIT(A) enhancing the income of the assessee u/s. 251(1)(a) r.w.s. 251(2) - The Ld. CIT(A) is not empowered to enhance the assessment by computing book profits U/s. 115JB of the Act, as it is a separate code. - This issue whether book profits can be computed U/s. 115JB of the Act, when the GTI and TI of the assessee are Nil and no taxes payable, is adjudicated in favour of the assessee - AT
Power of CIT(A) enhancing the income of the assessee u/s. 251(1)(a) r.w.s. 251(2) - The Ld. CIT(A) is not empowered to enhance the assessment by computing book profits U/s. 115JB of the Act, as it is a separate code. - This issue whether book profits can be computed U/s. 115JB of the Act, when the GTI and TI of the assessee are Nil and no taxes payable, is adjudicated in favour of the assessee - AT
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