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...
Section 96(a)(i) of the Direct Tax Vivad se Vishwas Scheme was held to exclude only assessments made under the specified search provisions under Sections 132 or 132A. Where the department itself recorded that the reassessment under Section 147 was founded on material impounded during survey under Section 133A, and the earlier Section 153C proceedings had been dropped, the exclusion could not be extended by combining the discarded search-based proceedings with the later survey-based reassessment. The exclusion being statutory required strict construction, and no additional restriction could be read in. The rejection of the declarations was illegal, and the petitioner was entitled to acceptance.
Section 96(a)(i) of the Direct Tax Vivad se Vishwas Scheme was held to exclude only assessments made under the specified search provisions under Sections 132 or 132A. Where the department itself recorded that the reassessment under Section 147 was founded on material impounded during survey under Section 133A, and the earlier Section 153C proceedings had been dropped, the exclusion could not be extended by combining the discarded search-based proceedings with the later survey-based reassessment. The exclusion being statutory required strict construction, and no additional restriction could be read in. The rejection of the declarations was illegal, and the petitioner was entitled to acceptance.
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