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...
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
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