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...
The note addresses a revision under review where the assessing officer accepted returned income without any discussion on whether foreign residential properties affect eligibility for the capital gains exemption on reinvestment in residential property. The Tribunal found the assessment order erroneous for lack of enquiry and failure to apply mind, making the Principal CIT's revision valid. Because the AO did not decide the proviso-based eligibility issue on merits, the Tribunal set aside the matter for fresh adjudication by the AO to determine entitlement to the exemption, allowing the appeal for statistical purposes.
The note addresses a revision under review where the assessing officer accepted returned income without any discussion on whether foreign residential properties affect eligibility for the capital gains exemption on reinvestment in residential property. The Tribunal found the assessment order erroneous for lack of enquiry and failure to apply mind, making the Principal CIT's revision valid. Because the AO did not decide the proviso-based eligibility issue on merits, the Tribunal set aside the matter for fresh adjudication by the AO to determine entitlement to the exemption, allowing the appeal for statistical purposes.
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