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...
Filling of Modified return after amalgamation - Effect of order of tribunal or court in respect of business reorganisation u/s 170A - The High Court observed that Section 170A of the Income Tax Act mandates that any assessment after a business reorganization should be based on the modified return. Since the scheme of amalgamation became effective from 01.04.2020, the petitioner's consolidated return after amalgamation should have been the basis for assessment. - Consequently, the matter remanded back to AO to make a reassessment on the basis of such consolidated return of income.
Filling of Modified return after amalgamation - Effect of order of tribunal or court in respect of business reorganisation u/s 170A - The High Court observed that Section 170A of the Income Tax Act mandates that any assessment after a business reorganization should be based on the modified return. Since the scheme of amalgamation became effective from 01.04.2020, the petitioner's consolidated return after amalgamation should have been the basis for assessment. - Consequently, the matter remanded back to AO to make a reassessment on the basis of such consolidated return of income.
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