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...
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Set off of brought forward business loss - mistakes in previous years for not claiming benefit of set-off - 8 years time limit provided in the statute - The ITAT found that the assessee had a legitimate assessed business loss from AY 2005-06, which was not set off against the business income in AY 2008-09 and 2009-10 due to an accountant's mistake. However, under Section 72 of the Act, such unadjusted business losses can be carried forward and set off against business income in up to 8 subsequent assessment years. The Tribunal concluded that the assessee was indeed eligible to set off the brought forward business loss against the business income of AY 2010-11, as it falls within the 8-year time limit.
Set off of brought forward business loss - mistakes in previous years for not claiming benefit of set-off - 8 years time limit provided in the statute - The ITAT found that the assessee had a legitimate assessed business loss from AY 2005-06, which was not set off against the business income in AY 2008-09 and 2009-10 due to an accountant's mistake. However, under Section 72 of the Act, such unadjusted business losses can be carried forward and set off against business income in up to 8 subsequent assessment years. The Tribunal concluded that the assessee was indeed eligible to set off the brought forward business loss against the business income of AY 2010-11, as it falls within the 8-year time limit.
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