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 single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.
A single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.
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