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...
Exemption u/s 11 - deemed grant of registration - The period of six months referred in Section 12AA(2) has to be calculated from the end of the months in which the application u/s 12A was received and not from any other date. - Tribunal was not justified in applying Section 12AA(2) of the Act, 1961 in the facts of the present case and the order of CIT could not have been set aside on this ground. The decision of the Tribunal is based on a misreading and misunderstanding of Section 12AA(2) of the Act, 1961, its purport and scope. - HC
Exemption u/s 11 - deemed grant of registration - The period of six months referred in Section 12AA(2) has to be calculated from the end of the months in which the application u/s 12A was received and not from any other date. - Tribunal was not justified in applying Section 12AA(2) of the Act, 1961 in the facts of the present case and the order of CIT could not have been set aside on this ground. The decision of the Tribunal is based on a misreading and misunderstanding of Section 12AA(2) of the Act, 1961, its purport and scope. - HC
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