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...
Business expenses - CSR - The expenditure could be related to ‘Commercial Expediency’, as any amount contributed to the BATF would generate goodwill of the local community as well as the Government Authorities. It must also be emphasised that the concept of ‘Commercial Expediency’ is from the perspective of an assessee and cannot be judged from the perspective of what the Revenue construes it to be ‘Commercial expediency.’ - As the subject matter of dispute relates to assessment year 2010-11, it can be stated that the said explanation to Section 37 of the I.T. Act would not apply as regards the present subject matter of dispute. - HC
Business expenses - CSR - The expenditure could be related to ‘Commercial Expediency’, as any amount contributed to the BATF would generate goodwill of the local community as well as the Government Authorities. It must also be emphasised that the concept of ‘Commercial Expediency’ is from the perspective of an assessee and cannot be judged from the perspective of what the Revenue construes it to be ‘Commercial expediency.’ - As the subject matter of dispute relates to assessment year 2010-11, it can be stated that the said explanation to Section 37 of the I.T. Act would not apply as regards the present subject matter of dispute. - HC
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