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...
A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.
A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
