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 based on a suspicious transaction report cannot stand on mere suspicion without material indicating income escapement. The HC noted that the assessee's accounts and detailed reply showed the questioned receipts were capital contributions or withdrawals between a partner and its partnership firm; a partner's withdrawal of its capital balance does not itself establish taxable income. Revenue identified no evidence or third-party information that the bank entries were bogus or accommodation entries, and no related interest claim was disputed. The show-cause notice, reassessment notice and reassessment order were quashed.
Reassessment based on a suspicious transaction report cannot stand on mere suspicion without material indicating income escapement. The HC noted that the assessee's accounts and detailed reply showed the questioned receipts were capital contributions or withdrawals between a partner and its partnership firm; a partner's withdrawal of its capital balance does not itself establish taxable income. Revenue identified no evidence or third-party information that the bank entries were bogus or accommodation entries, and no related interest claim was disputed. The show-cause notice, reassessment notice and reassessment order were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4780
Join Channel
TaxTMI 
