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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Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
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