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 10AA was denied where the assessee's own Form 56F and audit report showed nil export proceeds in convertible foreign exchange, and supplies to DTA or another SEZ were treated as non-qualifying absent proof of export out of India. Employees' PF and ESI contribution was disallowed because payment was made even beyond the EPFO grace period. Sundry balances written off failed for lack of supporting evidence. Bad debts written off were allowed once the amounts were recorded as irrecoverable in the accounts under TRF Ltd. Adjustment of patent-related liability against an investment was held not to attract section 41(1) because it was a capital asset transaction, not a trading liability. The section 10AA claim for AY 2018-19 was remanded for fresh verification of revised Form 56F.
Deduction under section 10AA was denied where the assessee's own Form 56F and audit report showed nil export proceeds in convertible foreign exchange, and supplies to DTA or another SEZ were treated as non-qualifying absent proof of export out of India. Employees' PF and ESI contribution was disallowed because payment was made even beyond the EPFO grace period. Sundry balances written off failed for lack of supporting evidence. Bad debts written off were allowed once the amounts were recorded as irrecoverable in the accounts under TRF Ltd. Adjustment of patent-related liability against an investment was held not to attract section 41(1) because it was a capital asset transaction, not a trading liability. The section 10AA claim for AY 2018-19 was remanded for fresh verification of revised Form 56F.
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