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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Under CBDT Instruction No. 1/2011, metro corporate returns up to the prescribed income limit remained with the ITO, while only higher-value cases fell within ACIT/DCIT jurisdiction. Because the assessee's returned income and income assessed under section 143(3) were both below that limit, the ACIT lacked monetary jurisdiction to issue the section 148 notice. The Tribunal treated this defect as going to the validity of the jurisdictional notice itself, held the notice invalid, and quashed the reassessment order as consequentially unsustainable.
Under CBDT Instruction No. 1/2011, metro corporate returns up to the prescribed income limit remained with the ITO, while only higher-value cases fell within ACIT/DCIT jurisdiction. Because the assessee's returned income and income assessed under section 143(3) were both below that limit, the ACIT lacked monetary jurisdiction to issue the section 148 notice. The Tribunal treated this defect as going to the validity of the jurisdictional notice itself, held the notice invalid, and quashed the reassessment order as consequentially unsustainable.
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