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...
Reassessment initiated after four years from the end of the assessment year was held invalid where the original assessment had been completed under scrutiny and the recorded reasons showed that the information on alleged accommodation entries was already available during that assessment. In the absence of any allegation in the reasons that the assessee had failed to disclose fully and truly all material facts, the jurisdictional requirement for reopening beyond four years was not met. The notice under section 148 and the consequential reassessment order were quashed, and the merits of the additions were left unexamined.
Reassessment initiated after four years from the end of the assessment year was held invalid where the original assessment had been completed under scrutiny and the recorded reasons showed that the information on alleged accommodation entries was already available during that assessment. In the absence of any allegation in the reasons that the assessee had failed to disclose fully and truly all material facts, the jurisdictional requirement for reopening beyond four years was not met. The notice under section 148 and the consequential reassessment order were quashed, and the merits of the additions were left unexamined.
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