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...
HC held that a best judgment assessment under Section 62 cannot stand unless the statutory notice preceding the assessment is proved to have been served in a mode recognised by Section 169. A mere recital in the assessment order that notice was issued was insufficient, and the respondents produced no material showing valid service before completion of the assessments. In the absence of proof of service of the mandatory notice, the impugned assessment orders were quashed and the matter was left open for fresh consideration after due notice, if warranted.
HC held that a best judgment assessment under Section 62 cannot stand unless the statutory notice preceding the assessment is proved to have been served in a mode recognised by Section 169. A mere recital in the assessment order that notice was issued was insufficient, and the respondents produced no material showing valid service before completion of the assessments. In the absence of proof of service of the mandatory notice, the impugned assessment orders were quashed and the matter was left open for fresh consideration after due notice, if warranted.
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