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(1)(a) and Section 11(2) for Deemed income u/s 11(3) - Assessee would be allowed to accumulate the income if there is “real income” which is in possession of the assessee - something which is not in possession of the assessee cannot be accumulated or utilized at a later date. - Therefore “deemed income” u/s 11(3) of the Act is not eligible for claim of exemption under Section 11(1)(a) and Section 11(2) of the Act. - AT
Exemption u/s 11(1)(a) and Section 11(2) for Deemed income u/s 11(3) - Assessee would be allowed to accumulate the income if there is “real income” which is in possession of the assessee - something which is not in possession of the assessee cannot be accumulated or utilized at a later date. - Therefore “deemed income” u/s 11(3) of the Act is not eligible for claim of exemption under Section 11(1)(a) and Section 11(2) of the Act. - AT
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