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...
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
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