Delayed judgment pronouncement alone does not invalidate Tribunal orders, while rectification cannot reopen evidence or negate confiscation-related pe...
Agricultural-land reinvestment qualifies when transfer consideration precedes replacement purchase, while unexamined claims may be reassessed on escap...
Bona fide public fixed-deposit explanations prevent concealment penalties where unexplained-credit additions lack independent evidence of undisclosed ...
Factory-consumption condition restricts solar module parts exemption and excludes imported aluminium profiles fabricated outside the production factor...
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PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim.
PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim.
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