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International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Section 153C jurisdiction requires a valid, year-specific satisfaction note identifying seized material belonging to or relating to the assessee and its bearing on income. A consolidated note based only on surrender letters does not satisfy this requirement, as surrender letters are not seized material. The six-year assessment block is reckoned from the deemed search year; years outside that block cannot be assessed under section 153C. Years within the block must be assessed through section 153C rather than regular assessment proceedings. For completed, unabated assessments, additions require incriminating material found during search; a change in revenue-recognition method without such material cannot support an addition.
Section 153C jurisdiction requires a valid, year-specific satisfaction note identifying seized material belonging to or relating to the assessee and its bearing on income. A consolidated note based only on surrender letters does not satisfy this requirement, as surrender letters are not seized material. The six-year assessment block is reckoned from the deemed search year; years outside that block cannot be assessed under section 153C. Years within the block must be assessed through section 153C rather than regular assessment proceedings. For completed, unabated assessments, additions require incriminating material found during search; a change in revenue-recognition method without such material cannot support an addition.
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