S. 115JB : Book profit-No addition will be made in respect of disallowance under section 14A, read with rule 8D-Benefit of clause (i) of Explanation 1 to section 115JB (2) will not be available to assessee if book profit was not increased by amount of provision made in year of making provision for whatever reason. [S. 14A, R.8D]
S. 115JB : Book profit-Exempt income-Credited to the profit and loss account-Reduced while computing book profit [S.10]
S. 115JB : Book profit-Amalgamation-Revaluation reserve-Up word adjustment made by the AO was deleted-Loss incurred on account of redemption of mutual fund could not be added in business profit. [S. 94]
S. 115JB : Book profit-Net worth turned positive-Discharged by he Sick Industrial Companies (Special Provisions) Act, 1985-Liable to be assessed on book profit-Matter remanded to pass speaking order-COVID 19 pandemic lockdown period would be excluded in computing 90 days total time limit for pronouncing appellate order. [S. 255, SICAS. S. 17]
S. 115JB : Book profit-Net worth turned positive-Discharged by he Sick Industrial Companies (Special Provisions) Act, 1985-Liable to be assessed on book profit-Matter remanded to pass speaking order-COVID 19 pandemic lockdown period would be excluded in computing 90 days total time limit for pronouncing appellate order. [S.255, SICAS S. 17]
S. 115JB : Book profit-Net worth turned positive-Discharged by he Sick Industrial Companies (Special Provisions) Act, 1985-Liable to be assessed on book profit-Matter remanded to pass speaking order-COVID 19 pandemic lockdown period would be excluded in computing 90 days total time limit for pronouncing appellate order. [S. 255, SICAS S. 17]
S. 92C : Transfer pricing-Arm’s length price-Working capital-Captive service provider-No negative working capital adjustment could be made.
S. 92C : Transfer pricing-Arm’s length price-Royalty-Bench mark analysis-Matter remanded.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Shown margin of 9.02 per cent as against average margin of final comparables adopted by TPO at 22.69 per cent-High Turnover having brand value to be excluded-Matter remanded to TPO for denovo consideration-Provisions for bad debts as non-operating expenditure only in case of three comparable companies-Foreign exchange loss being not an extra-ordinary item in relevant year to assessee alone and similar loss being incurred by comparable companies, it was not a distinguishing factor to be considered for arriving at ALP.
S. 92C : Transfer pricing-Arm’s length price-Allowability of expenditure-TPO has no authority to disallow the expenditure-ALP adjustment cannot be equated with disallowance of expenses. [S. 37(1)]