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...
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Reassessment initiated after three years from the end of the relevant assessment year required approval from the authority specified in section 151(ii). The Finance Act 2023 proviso to section 151, effective from 1 April 2023, operated prospectively and could not be treated as retrospective merely as a clarification. Extensions or exclusions under section 149 could not be imported into section 151 to extend the three-year period. As sanction under section 151 is a jurisdictional condition precedent, approval by the Principal Commissioner instead of the specified competent authority rendered the notice, order under section 148A(d), and consequential reassessment proceedings void ab initio and liable to be quashed.
Reassessment initiated after three years from the end of the relevant assessment year required approval from the authority specified in section 151(ii). The Finance Act 2023 proviso to section 151, effective from 1 April 2023, operated prospectively and could not be treated as retrospective merely as a clarification. Extensions or exclusions under section 149 could not be imported into section 151 to extend the three-year period. As sanction under section 151 is a jurisdictional condition precedent, approval by the Principal Commissioner instead of the specified competent authority rendered the notice, order under section 148A(d), and consequential reassessment proceedings void ab initio and liable to be quashed.
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