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...
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
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