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...
Revision under section 263 cannot extend to matters already considered in an appeal: where the appeal covered the genuineness of purchases and profit estimation, Explanation 1(c) barred revision on those purchases. Revision also cannot substitute the Commissioner's view for the Assessing Officer's plausible view after inquiry; having examined supporting documents and estimated only the profit element in unverifiable purchases, the assessment could not be revised to tax the entire purchases as unexplained expenditure. Further, a supplier's non-genuineness alone does not establish remission or cessation of a trading liability, so the outstanding credit could not be taxed on that basis. The revisionary order was set aside and the appeal allowed.
Revision under section 263 cannot extend to matters already considered in an appeal: where the appeal covered the genuineness of purchases and profit estimation, Explanation 1(c) barred revision on those purchases. Revision also cannot substitute the Commissioner's view for the Assessing Officer's plausible view after inquiry; having examined supporting documents and estimated only the profit element in unverifiable purchases, the assessment could not be revised to tax the entire purchases as unexplained expenditure. Further, a supplier's non-genuineness alone does not establish remission or cessation of a trading liability, so the outstanding credit could not be taxed on that basis. The revisionary order was set aside and the appeal allowed.
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