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...
Computation of deduction u/ss 80IB/80IC and 10B - AO allocated Head Office expenses to eligible units, reducing deduction. Tribunal consistently restores issue with directions to allocate common expenses and income to eligible units. Miscellaneous income from sale of scraps/by-products in eligible units held eligible for deduction. Adjustment for CENVAT credit u/s 145A - issue restored to AO to examine assessee's claim. Expenditure on relief materials for Tsunami victims disallowed as not wholly and exclusively for business u/s 37(1), not allowable as sales promotion or CSR expenses. Insurance claim amount to be added to WDV, not treated as capital receipt. Capital subsidy not to be reduced from WDV for depreciation. Rate of tax on dividend to non-residents decided against assessee by Special Bench. Transfer pricing adjustment at entity level under TNMM accepted following earlier year order.
Computation of deduction u/ss 80IB/80IC and 10B - AO allocated Head Office expenses to eligible units, reducing deduction. Tribunal consistently restores issue with directions to allocate common expenses and income to eligible units. Miscellaneous income from sale of scraps/by-products in eligible units held eligible for deduction. Adjustment for CENVAT credit u/s 145A - issue restored to AO to examine assessee's claim. Expenditure on relief materials for Tsunami victims disallowed as not wholly and exclusively for business u/s 37(1), not allowable as sales promotion or CSR expenses. Insurance claim amount to be added to WDV, not treated as capital receipt. Capital subsidy not to be reduced from WDV for depreciation. Rate of tax on dividend to non-residents decided against assessee by Special Bench. Transfer pricing adjustment at entity level under TNMM accepted following earlier year order.
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