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 assessments under section 153C, the limitation period is stated to commence when the other person's records are transferred to the Assessing Officer handling the searched group under section 127. The subsequent recording of a satisfaction note does not postpone that commencement. Applying this principle, the reported Tribunal decision treated the assessments for the relevant assessment years as time-barred and quashed them, while leaving the remaining grounds open.
For assessments under section 153C, the limitation period is stated to commence when the other person's records are transferred to the Assessing Officer handling the searched group under section 127. The subsequent recording of a satisfaction note does not postpone that commencement. Applying this principle, the reported Tribunal decision treated the assessments for the relevant assessment years as time-barred and quashed them, while leaving the remaining grounds open.
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