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 11 - Reopening of assessment u/s 147 - whether jurisdiction was vested on the ld. CIT(E) and not with the Territorial Commissioner? - the registration U/s 12AA is in action from the year of application. So, the year of application is considered as deemed registration and the claim of deduction u/s 11 and 12 should be applicable accordingly. Accordingly, the assessing authority had acted beyond jurisdiction. - AT
Exemption u/s 11 - Reopening of assessment u/s 147 - whether jurisdiction was vested on the ld. CIT(E) and not with the Territorial Commissioner? - the registration U/s 12AA is in action from the year of application. So, the year of application is considered as deemed registration and the claim of deduction u/s 11 and 12 should be applicable accordingly. Accordingly, the assessing authority had acted beyond jurisdiction. - AT
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