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 for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
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