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...
Revision u/s 263 - correct head of income - while we see no reason to interfere with the order of the Commissioner under Section 263 of the Income Tax Act to the extent it remands the matter to the assessing authority for determining the nature of the income - whether business income or income from other sources - we set aside those findings of the Commissioner in Annexure E order that decides the issue on merits and leaves, no scope for an enquiry by the assessing authority - HC
Revision u/s 263 - correct head of income - while we see no reason to interfere with the order of the Commissioner under Section 263 of the Income Tax Act to the extent it remands the matter to the assessing authority for determining the nature of the income - whether business income or income from other sources - we set aside those findings of the Commissioner in Annexure E order that decides the issue on merits and leaves, no scope for an enquiry by the assessing authority - HC
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