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...
Non-consideration of the assessee's replies before issuing a reassessment notice can vitiate the order where the statute requires those explanations to be examined before forming a view on escaped income. The text notes that the impugned order dealt only partially with the materials filed and did not analyse the commercial rationale or the specific explanations offered, so the formation of belief lacked a sustainable basis. The order and consequential notice were quashed, and the matter was remitted for fresh consideration after granting an opportunity of hearing and passing a reasoned order.
Non-consideration of the assessee's replies before issuing a reassessment notice can vitiate the order where the statute requires those explanations to be examined before forming a view on escaped income. The text notes that the impugned order dealt only partially with the materials filed and did not analyse the commercial rationale or the specific explanations offered, so the formation of belief lacked a sustainable basis. The order and consequential notice were quashed, and the matter was remitted for fresh consideration after granting an opportunity of hearing and passing a reasoned order.
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