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 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
Revision u/s 263 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
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