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...
Reassessment under section 148 was quashed because the recorded reasons were vague, factually inconsistent and unsupported by an independent application of mind. The Tribunal found that the Assessing Officer relied on portal information and investigation material alleging fictitious profit, but the reassessment order treated the same figure differently and failed to maintain the very basis on which jurisdiction was assumed. No live nexus was shown between the material and escapement of income, and the assessee's purchase, sale, bank and D-Mat records were not dislodged by adverse material. The reopening was held to rest on borrowed satisfaction, so the reassessment was unsustainable and the merits were not examined.
Reassessment under section 148 was quashed because the recorded reasons were vague, factually inconsistent and unsupported by an independent application of mind. The Tribunal found that the Assessing Officer relied on portal information and investigation material alleging fictitious profit, but the reassessment order treated the same figure differently and failed to maintain the very basis on which jurisdiction was assumed. No live nexus was shown between the material and escapement of income, and the assessee's purchase, sale, bank and D-Mat records were not dislodged by adverse material. The reopening was held to rest on borrowed satisfaction, so the reassessment was unsustainable and the merits were not examined.
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