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...
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ITAT held that reopening for AY 2016-17 failed because the Revenue did not allege escapement represented in the form of an asset, so jurisdiction under the search-based block was invalid; the assessment was quashed. It also held that the enhanced tax rate under section 115BBE applied only from 01.04.2017, so it could not be levied for AY 2017-18. Additions for alleged over-invoicing and bogus purchases were deleted because the books and quantitative records were not rejected and the claimed purchases matched the amounts actually billed and paid. CSR expenditure remained disallowable as business expense, but the alternative deduction claim was remanded for fresh examination.
ITAT held that reopening for AY 2016-17 failed because the Revenue did not allege escapement represented in the form of an asset, so jurisdiction under the search-based block was invalid; the assessment was quashed. It also held that the enhanced tax rate under section 115BBE applied only from 01.04.2017, so it could not be levied for AY 2017-18. Additions for alleged over-invoicing and bogus purchases were deleted because the books and quantitative records were not rejected and the claimed purchases matched the amounts actually billed and paid. CSR expenditure remained disallowable as business expense, but the alternative deduction claim was remanded for fresh examination.
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