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...
Penalty proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.
Penalty proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.
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