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...
Addition u/s 56(2) - “Property” as defined in explanation (d) (ii) of section 56(2)(vii) makes distinction between the existing shares i.e. the shares already allotted by the company and those share which are pending allotment or not? - application of admission of additional evidence - The Tribunal observed that the issues raised were decided on merits, considering facts and applicable laws. However, due to additional information and grounds presented by the assessee, which were not available to the lower authorities, the Tribunal found it just to restore the matter to the file of the CIT(A) for fresh adjudication.
Addition u/s 56(2) - “Property” as defined in explanation (d) (ii) of section 56(2)(vii) makes distinction between the existing shares i.e. the shares already allotted by the company and those share which are pending allotment or not? - application of admission of additional evidence - The Tribunal observed that the issues raised were decided on merits, considering facts and applicable laws. However, due to additional information and grounds presented by the assessee, which were not available to the lower authorities, the Tribunal found it just to restore the matter to the file of the CIT(A) for fresh adjudication.
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