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...
Section 12AB(4) cancellation for specified violation is stated to operate prospectively from 01.04.2022, so a cancellation based on alleged breaches from FY 2014-15 was treated as retrospective application not permitted by the statute. The text further notes that reliance on section 12AA after its omission from 01.04.2021 was inconsistent with the statutory framework, and jurisdiction under section 12AB(4) could not arise without a specified violation after 01.04.2022. On merits, the alleged expenses were said to support religious and charitable objects, while valuation issues, accounting lapses and procedural defects did not establish non-genuineness or false information. The cancellation was therefore described as unsustainable.
Section 12AB(4) cancellation for specified violation is stated to operate prospectively from 01.04.2022, so a cancellation based on alleged breaches from FY 2014-15 was treated as retrospective application not permitted by the statute. The text further notes that reliance on section 12AA after its omission from 01.04.2021 was inconsistent with the statutory framework, and jurisdiction under section 12AB(4) could not arise without a specified violation after 01.04.2022. On merits, the alleged expenses were said to support religious and charitable objects, while valuation issues, accounting lapses and procedural defects did not establish non-genuineness or false information. The cancellation was therefore described as unsustainable.
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