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 requires a valid jurisdictional notice under section 143(2). Where a private company converted into an LLP and the Assessing Officer was notified of the conversion, issuing that notice and completing reassessment in the name of the erstwhile company rendered the proceedings invalid. A company and an LLP have separate legal identities and different tax treatment; assessment of the non-existent company was therefore a substantive illegality, not a procedural defect capable of cure under section 292B. The reassessment orders were void from inception and quashed, while remaining grounds became academic.
Reassessment requires a valid jurisdictional notice under section 143(2). Where a private company converted into an LLP and the Assessing Officer was notified of the conversion, issuing that notice and completing reassessment in the name of the erstwhile company rendered the proceedings invalid. A company and an LLP have separate legal identities and different tax treatment; assessment of the non-existent company was therefore a substantive illegality, not a procedural defect capable of cure under section 292B. The reassessment orders were void from inception and quashed, while remaining grounds became academic.
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