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...
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
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