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...
Filing of revised return - denial of loss - Considering the revised return date as belated return, whereas original ITR was filed in time - the intimation under challenge has not considered the fact that the return filed on 15.01.2020 was not the original return but was revised one and therefore, the denial of loss is not correct based on the set of facts and evidence available on records. - Claim allowed - AT
Filing of revised return - denial of loss - Considering the revised return date as belated return, whereas original ITR was filed in time - the intimation under challenge has not considered the fact that the return filed on 15.01.2020 was not the original return but was revised one and therefore, the denial of loss is not correct based on the set of facts and evidence available on records. - Claim allowed - AT
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