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 assessee's short-term capital gains from share trading were rightly treated as business income. Mere mention of shares as investments does not grant benefit under Circular No.4 of 2007. Separate account maintenance, delivery-based transactions, and acceptance of capital gains in preceding years were not sufficient to establish share trading as investments. The assessee was eligible for deduction u/s 80IC as the manufacturing unit was located in a notified area, fulfilling conditions. Disallowance of 20% of milk purchases was unjustified as expenses were duly debited, and net profit ratio was considered for assessment in subsequent years. The Tribunal allowed the assessee's claim, finding no justification for discrediting purchases on an ad hoc basis.
The assessee's short-term capital gains from share trading were rightly treated as business income. Mere mention of shares as investments does not grant benefit under Circular No.4 of 2007. Separate account maintenance, delivery-based transactions, and acceptance of capital gains in preceding years were not sufficient to establish share trading as investments. The assessee was eligible for deduction u/s 80IC as the manufacturing unit was located in a notified area, fulfilling conditions. Disallowance of 20% of milk purchases was unjustified as expenses were duly debited, and net profit ratio was considered for assessment in subsequent years. The Tribunal allowed the assessee's claim, finding no justification for discrediting purchases on an ad hoc basis.
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