Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
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ITAT allowed the appeal, holding that s.115BAB (concessional tax on income of new manufacturing domestic companies) and related adjustment provisions are inapplicable where the assessee has not commenced business and has no taxable income. The Tribunal found no profit even after adjustments, and therefore there was no basis to grant or deny a concessional rate, nor to invoke rules concerning shifting of profit or specified domestic transactions for the year under review. Consequently, no adjustment under the concessional-tax provisions was warranted and the ground raised by the assessee was allowed.
ITAT allowed the appeal, holding that s.115BAB (concessional tax on income of new manufacturing domestic companies) and related adjustment provisions are inapplicable where the assessee has not commenced business and has no taxable income. The Tribunal found no profit even after adjustments, and therefore there was no basis to grant or deny a concessional rate, nor to invoke rules concerning shifting of profit or specified domestic transactions for the year under review. Consequently, no adjustment under the concessional-tax provisions was warranted and the ground raised by the assessee was allowed.
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