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 adjudicated multiple taxation issues involving property-related income and interest deductions. The tribunal held that: (1) reassessment notice issued to a non-existing entity was null and void, quashing the re-assessment order; (2) pre-construction interest deduction under Section 24(b) was allowable for the entire Rs. 30 Crore loan utilized for property acquisition, rejecting proportionate disallowance; (3) maintenance charges from lessees were correctly classified as business income; and (4) loan substitution for property acquisition was acceptable, permitting interest deduction when nexus between loan and property was established. The tribunal ultimately confirmed the lower appellate authority's order in favor of the assessee.
ITAT adjudicated multiple taxation issues involving property-related income and interest deductions. The tribunal held that: (1) reassessment notice issued to a non-existing entity was null and void, quashing the re-assessment order; (2) pre-construction interest deduction under Section 24(b) was allowable for the entire Rs. 30 Crore loan utilized for property acquisition, rejecting proportionate disallowance; (3) maintenance charges from lessees were correctly classified as business income; and (4) loan substitution for property acquisition was acceptable, permitting interest deduction when nexus between loan and property was established. The tribunal ultimately confirmed the lower appellate authority's order in favor of the assessee.
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