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...
Exempt dividend income treated as taxable, increasing total income - claim denied by processing return u/s 143(1). Assessee filed rectification application u/s 154 pending before CPC, Bengaluru. Application to be disposed expeditiously, and no adverse action against assessee till disposal. TP adjustment on intra-group support services - settled through unilateral APA between CBDT and assessee for 5 years from 2015-16 to 2019-20, including assessment year. AO to re-decide issue considering APA and modified return. Deduction u/s 80G for CSR expenditure - DRP concluded deduction allowed except for donations to Swachh Bharat Kosh and Clean Ganga Fund, subject to section 80G conditions. Issue remanded to AO to pass final order conforming to DRP directions. Interest u/s 234A - challenged on grounds of timely filing before extended due date. AO to verify extended date and levy interest only if return filed after extended date. Interest u/s 234B to be levied by AO after giving appeal effect. Non-granting of DDT credit - AO to verify claim from challan and allow credit if correct.
Exempt dividend income treated as taxable, increasing total income - claim denied by processing return u/s 143(1). Assessee filed rectification application u/s 154 pending before CPC, Bengaluru. Application to be disposed expeditiously, and no adverse action against assessee till disposal. TP adjustment on intra-group support services - settled through unilateral APA between CBDT and assessee for 5 years from 2015-16 to 2019-20, including assessment year. AO to re-decide issue considering APA and modified return. Deduction u/s 80G for CSR expenditure - DRP concluded deduction allowed except for donations to Swachh Bharat Kosh and Clean Ganga Fund, subject to section 80G conditions. Issue remanded to AO to pass final order conforming to DRP directions. Interest u/s 234A - challenged on grounds of timely filing before extended due date. AO to verify extended date and levy interest only if return filed after extended date. Interest u/s 234B to be levied by AO after giving appeal effect. Non-granting of DDT credit - AO to verify claim from challan and allow credit if correct.
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