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...
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
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