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...
Legal issues related to income tax assessments, including the designation of tax authorities, allowability of deductions, disallowances under specific sections, transfer pricing adjustments, and procedural aspects. Key points are: Designation of Additional Commissioner as TPO is valid. Pro-rata deduction for leasehold lands allowed, subject to quantum verification. Write-back of provision for doubtful debts remitted for re-examination. Interest on tax refund to be granted as per assessee's claim. Disallowance u/r 8D restricted to exempt income-yielding investments. Such disallowance not applicable for computing book profits u/s 115JB. Expenditure on FCCN issue allowed as debenture issuance cost. Deduction u/s 80G disallowed due to loss. Transfer pricing adjustments on export of vehicles and interest on loans to AEs remitted for re-adjudication. Adjustments on purchase of property from AE and rent from leased property to AE deleted. TDS credit short allowed. Interest u/s 234D upheld. Additional ground regarding time-barred assessment dismissed based on precedent. Concise coverage of critical issues using relevant terminology.
Legal issues related to income tax assessments, including the designation of tax authorities, allowability of deductions, disallowances under specific sections, transfer pricing adjustments, and procedural aspects. Key points are: Designation of Additional Commissioner as TPO is valid. Pro-rata deduction for leasehold lands allowed, subject to quantum verification. Write-back of provision for doubtful debts remitted for re-examination. Interest on tax refund to be granted as per assessee's claim. Disallowance u/r 8D restricted to exempt income-yielding investments. Such disallowance not applicable for computing book profits u/s 115JB. Expenditure on FCCN issue allowed as debenture issuance cost. Deduction u/s 80G disallowed due to loss. Transfer pricing adjustments on export of vehicles and interest on loans to AEs remitted for re-adjudication. Adjustments on purchase of property from AE and rent from leased property to AE deleted. TDS credit short allowed. Interest u/s 234D upheld. Additional ground regarding time-barred assessment dismissed based on precedent. Concise coverage of critical issues using relevant terminology.
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