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 bad debts written off - bad debts in respect of subscriptions defaulted by the prized subscribers - The Tribunal found the CIT(A)'s decision well-founded, particularly in light of the specific judicial pronouncements and the ITAT Hyderabad's stance, which had, in principle, allowed the claim of bad debts related to chit funds while remanding the matter for factual verification. Moreover, the Tribunal noted that the relationship between chit fund transactions did not characterize a typical debtor-creditor scenario, aligning with the principles laid out in significant judgments.
Disallowance of bad debts written off - bad debts in respect of subscriptions defaulted by the prized subscribers - The Tribunal found the CIT(A)'s decision well-founded, particularly in light of the specific judicial pronouncements and the ITAT Hyderabad's stance, which had, in principle, allowed the claim of bad debts related to chit funds while remanding the matter for factual verification. Moreover, the Tribunal noted that the relationship between chit fund transactions did not characterize a typical debtor-creditor scenario, aligning with the principles laid out in significant judgments.
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