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...
For reassessment notices issued more than three years after the relevant assessment year, prior approval for the order under section 148A(d) and notice under section 148 must come from the authority specified in section 151(ii): the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General. Approval by a Principal Commissioner is not valid sanction after that period because that authority lacks statutory competence. A later provision characterising approvals as administrative and supervisory does not cure sanction granted by an unauthorised authority. Reassessment initiated on such invalid approval is liable to be quashed for lack of jurisdiction, while unrelated merits issues remain open.
For reassessment notices issued more than three years after the relevant assessment year, prior approval for the order under section 148A(d) and notice under section 148 must come from the authority specified in section 151(ii): the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General. Approval by a Principal Commissioner is not valid sanction after that period because that authority lacks statutory competence. A later provision characterising approvals as administrative and supervisory does not cure sanction granted by an unauthorised authority. Reassessment initiated on such invalid approval is liable to be quashed for lack of jurisdiction, while unrelated merits issues remain open.
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