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...
Under section 11, a trust could set off excess charitable expenditure of earlier years against income of the subsequent year for AY 2017-18, because pre-01/04/2022 law contained no restriction that income must be applied only in the year it arose. The Finance Act, 2021 insertion of Explanation 5 to section 11(1), which bars such set-off, was treated as prospective from 01/04/2022. The claim could not be rejected for want of Form 9A, as that form was not required for this adjustment. The ITAT remitted the matter to the Assessing Officer only to verify the carried forward deficit and supporting records before granting relief.
Under section 11, a trust could set off excess charitable expenditure of earlier years against income of the subsequent year for AY 2017-18, because pre-01/04/2022 law contained no restriction that income must be applied only in the year it arose. The Finance Act, 2021 insertion of Explanation 5 to section 11(1), which bars such set-off, was treated as prospective from 01/04/2022. The claim could not be rejected for want of Form 9A, as that form was not required for this adjustment. The ITAT remitted the matter to the Assessing Officer only to verify the carried forward deficit and supporting records before granting relief.
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