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...
Sections 144C and 153 require harmonious construction when determining limitation for a final assessment made pursuant to DRP directions. The non-obstante clause in section 144C(13) does not displace the outer time limit under section 153; the final assessment must therefore be completed within that prescribed limitation period. Applying the binding High Court precedent, the ITAT treated the final assessment for Assessment Year 2018-19 as time-barred and quashed it. Merits grounds remained open, with liberty to seek revival if a Supreme Court decision requires modification.
Sections 144C and 153 require harmonious construction when determining limitation for a final assessment made pursuant to DRP directions. The non-obstante clause in section 144C(13) does not displace the outer time limit under section 153; the final assessment must therefore be completed within that prescribed limitation period. Applying the binding High Court precedent, the ITAT treated the final assessment for Assessment Year 2018-19 as time-barred and quashed it. Merits grounds remained open, with liberty to seek revival if a Supreme Court decision requires modification.
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