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...
Revision u/s 263 by CIT - direction to the AO to compute income of the appellant Trust without allowing exemption u/s. 10(23C)(iiiae) - All the conditions as prescribed u/s.10(23C)(iiiae) of the Act, have been fulfilled by the appellant Trust and there is no allegation that the appellant Trust is involved in any other activity for profit or does not exist for philanthropic purposes. Even in this case, all the facts are on the file, therefore there was no need for any further investigation by the A.O. as alleged by the Ld. CIT(E). - AT
Revision u/s 263 by CIT - direction to the AO to compute income of the appellant Trust without allowing exemption u/s. 10(23C)(iiiae) - All the conditions as prescribed u/s.10(23C)(iiiae) of the Act, have been fulfilled by the appellant Trust and there is no allegation that the appellant Trust is involved in any other activity for profit or does not exist for philanthropic purposes. Even in this case, all the facts are on the file, therefore there was no need for any further investigation by the A.O. as alleged by the Ld. CIT(E). - AT
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