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...
Limitation for assessment under the amended timeline was upheld: the substituted second proviso to section 153(1) extended the time for passing the assessment order for AY 2020-21 to 30.09.2022, so an order dated 28.09.2022 was within time. In faceless assessment, service of a draft assessment order was held necessary only for an eligible assessee; for an ordinary assessee, disclosure through a show-cause notice satisfied the statute. The objection of denial of personal hearing failed because the notice permitted a video-conference hearing and no request was made. Merits-based objections involving disputed facts were left to the statutory appellate forum, and the writ petitions were dismissed with protection on limitation for appeals.
Limitation for assessment under the amended timeline was upheld: the substituted second proviso to section 153(1) extended the time for passing the assessment order for AY 2020-21 to 30.09.2022, so an order dated 28.09.2022 was within time. In faceless assessment, service of a draft assessment order was held necessary only for an eligible assessee; for an ordinary assessee, disclosure through a show-cause notice satisfied the statute. The objection of denial of personal hearing failed because the notice permitted a video-conference hearing and no request was made. Merits-based objections involving disputed facts were left to the statutory appellate forum, and the writ petitions were dismissed with protection on limitation for appeals.
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