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 of exemption u/s.10AA - assessee did not have adequate and sufficient fixed assets, manpower and power/ fuel to carry out any manufacturing or processing activity to the extent shown by the assessee - The law is well settled that a person who claims exemption or concession has to establish that he is entitled to that exemption or concession. A provision providing for an exemption, concession or exception, as the case may be, has to be construed strictly. Therefore, we set aside the order of ld CIT(A) and remit this issue back to the file of the assessing officer to examine the conditions of section 10AA of the Act and SEZ Act and adjudicate the issue afresh in accordance with law. - AT
Disallowance of exemption u/s.10AA - assessee did not have adequate and sufficient fixed assets, manpower and power/ fuel to carry out any manufacturing or processing activity to the extent shown by the assessee - The law is well settled that a person who claims exemption or concession has to establish that he is entitled to that exemption or concession. A provision providing for an exemption, concession or exception, as the case may be, has to be construed strictly. Therefore, we set aside the order of ld CIT(A) and remit this issue back to the file of the assessing officer to examine the conditions of section 10AA of the Act and SEZ Act and adjudicate the issue afresh in accordance with law. - AT
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