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...
ITAT ruled on a trust's tax exemption under section 11, addressing multiple key issues: The tribunal held that exemption denial under section 13 should be limited only to the specific income violating provisions, not the entire trust income. The maximum marginal rate shall apply exclusively to the contravened income portion (Rs. 1,80,000), not the complete trust income. Regarding section 69A, impounded unverified documents were deemed insufficient for making unexplained income additions. The tribunal allowed exemption under section 11, permitted depreciation claim as an application of income, and confirmed that the trust could claim either depreciation or capital expenditure application, ensuring statutory compliance while preventing potential administrative overreach.
ITAT ruled on a trust's tax exemption under section 11, addressing multiple key issues: The tribunal held that exemption denial under section 13 should be limited only to the specific income violating provisions, not the entire trust income. The maximum marginal rate shall apply exclusively to the contravened income portion (Rs. 1,80,000), not the complete trust income. Regarding section 69A, impounded unverified documents were deemed insufficient for making unexplained income additions. The tribunal allowed exemption under section 11, permitted depreciation claim as an application of income, and confirmed that the trust could claim either depreciation or capital expenditure application, ensuring statutory compliance while preventing potential administrative overreach.
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