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...
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
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