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 10(23C) (vi) - rejection of the application u/s 12AA - allegation of paying interest on unsecured loan to specified persons at higher rate - Whether paying the interest at the rate of 9%/12% to the above then person was a benefit to the specified person, was required to be examined by the AO during the assessment proceedings and for that purposes it was incumbent upon the AO to bring on record the contemporaneous comparative instances of the similar society indicating that the interest of rate paid by the assessee was far more than that was prevailing in the open market. In the light of the above, the first objection raised by the CIT(E) was without any basis. - AT
Exemption u/s 10(23C) (vi) - rejection of the application u/s 12AA - allegation of paying interest on unsecured loan to specified persons at higher rate - Whether paying the interest at the rate of 9%/12% to the above then person was a benefit to the specified person, was required to be examined by the AO during the assessment proceedings and for that purposes it was incumbent upon the AO to bring on record the contemporaneous comparative instances of the similar society indicating that the interest of rate paid by the assessee was far more than that was prevailing in the open market. In the light of the above, the first objection raised by the CIT(E) was without any basis. - AT
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