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...
Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.
Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.
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