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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Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
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