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 - claiming benefit of accumulation u/s 11(2) over deemed income u/s 11(3) - non application of income - the assessee should not be eligible to claim double deduction in respect of the same income i.e. recycle the same income, which remained unapplied after the end of the fifth year. Therefore, if exemption under section 11(1)(a)is allowable in respect of the deemed income u/s 11(3), then exemption u/s 11(2) is also allowable in respect of such deemed income as sub-section (2) of section 11 refers to the income referred to in section 11(1)(a). - AT
Exemption u/s 11 - claiming benefit of accumulation u/s 11(2) over deemed income u/s 11(3) - non application of income - the assessee should not be eligible to claim double deduction in respect of the same income i.e. recycle the same income, which remained unapplied after the end of the fifth year. Therefore, if exemption under section 11(1)(a)is allowable in respect of the deemed income u/s 11(3), then exemption u/s 11(2) is also allowable in respect of such deemed income as sub-section (2) of section 11 refers to the income referred to in section 11(1)(a). - AT
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