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...
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
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