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...
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
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