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 based only on Investigation Wing material was held invalid where the recorded reasons showed no independent inquiry, no tangible material and no live nexus between the information and alleged escapement; in cases reopened beyond four years after scrutiny assessment, the absence of any identified failure to disclose fully and truly also barred jurisdiction. On merits, additions treating share sale proceeds as unexplained credits were deleted because the assessees had already disclosed the corresponding capital gains or losses and supported the transactions with contract notes, bank and demat records, broker ledgers and tax evidence, making a further addition impermissible double addition. General investigation or SEBI material without assessee-specific linkage could not sustain a penny stock allegation. Consequential commission additions were also deleted.
Reassessment based only on Investigation Wing material was held invalid where the recorded reasons showed no independent inquiry, no tangible material and no live nexus between the information and alleged escapement; in cases reopened beyond four years after scrutiny assessment, the absence of any identified failure to disclose fully and truly also barred jurisdiction. On merits, additions treating share sale proceeds as unexplained credits were deleted because the assessees had already disclosed the corresponding capital gains or losses and supported the transactions with contract notes, bank and demat records, broker ledgers and tax evidence, making a further addition impermissible double addition. General investigation or SEBI material without assessee-specific linkage could not sustain a penny stock allegation. Consequential commission additions were also deleted.
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