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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The ITAT held that exemption u/s 10(23C) was disallowed due to non-filing of audit report in Form 10BB. Assessee not registered u/s 10(23), ineligible for exemption. Net income to be taxed after allowable expenditure deduction. Remanded to AO to tax net income after deducting expenses like regular, salary, puja, and admissible expenditure. CIT (A) erred in not addressing eligibility issue. Assessee to be assessed as AOP. Issue of eligibility to claim u/s 10(23) to be reconsidered by CIT (A) with opportunity for assessee to present evidence. Remanded for fresh adjudication.
The ITAT held that exemption u/s 10(23C) was disallowed due to non-filing of audit report in Form 10BB. Assessee not registered u/s 10(23), ineligible for exemption. Net income to be taxed after allowable expenditure deduction. Remanded to AO to tax net income after deducting expenses like regular, salary, puja, and admissible expenditure. CIT (A) erred in not addressing eligibility issue. Assessee to be assessed as AOP. Issue of eligibility to claim u/s 10(23) to be reconsidered by CIT (A) with opportunity for assessee to present evidence. Remanded for fresh adjudication.
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