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...
A return filed in response to a notice under section 148, when filed within the period specified in that notice, is treated under section 148(2) as a return furnished under section 139. Read together, sections 148 and 80AC permit a deduction claim where the reassessment return is timely, notwithstanding that no original return was filed under section 139(1). The text also explains that revision under section 263 is not warranted where the assessment record shows that the deduction claim was examined and allowed after application of mind; the assessment order must be both erroneous and prejudicial to Revenue interests.
A return filed in response to a notice under section 148, when filed within the period specified in that notice, is treated under section 148(2) as a return furnished under section 139. Read together, sections 148 and 80AC permit a deduction claim where the reassessment return is timely, notwithstanding that no original return was filed under section 139(1). The text also explains that revision under section 263 is not warranted where the assessment record shows that the deduction claim was examined and allowed after application of mind; the assessment order must be both erroneous and prejudicial to Revenue interests.
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