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...
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.
Note: It is a system-generated summary and is for quick reference only.