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...
Disallowance u/s 14A - Disallowing interest expense - Neither the assessee furnished the working of disallowances under section 14A, nor the lower authority made the disallowance as per the formula prescribed under Rule 8D, therefore, we restore the matter back to the file of Assessing Officer to re-compute/ rework the disallowance under section 14A read with Rule 8D. The assessee is also directed to explain the working of disallowance under section 14A before the Assessing Officer as and when called for. - AT
Disallowance u/s 14A - Disallowing interest expense - Neither the assessee furnished the working of disallowances under section 14A, nor the lower authority made the disallowance as per the formula prescribed under Rule 8D, therefore, we restore the matter back to the file of Assessing Officer to re-compute/ rework the disallowance under section 14A read with Rule 8D. The assessee is also directed to explain the working of disallowance under section 14A before the Assessing Officer as and when called for. - AT
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