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 additions based solely on material gathered after reopening cannot survive where no addition or modification is made on the issue that formed the basis for reopening. Although the Explanation to section 147 permits assessment of subsequently noticed income after a valid reopening, the Tribunal applied the principle that this power depends on making an addition on the foundational reopening issue. The condition applies equally to reassessment following search where section 148A procedure is dispensed with. As the Revenue did not establish any addition based on material available at initiation, all additions arising from subsequent enquiries and verification were deleted. Both appeals were allowed, with remaining grounds left open.
Reassessment additions based solely on material gathered after reopening cannot survive where no addition or modification is made on the issue that formed the basis for reopening. Although the Explanation to section 147 permits assessment of subsequently noticed income after a valid reopening, the Tribunal applied the principle that this power depends on making an addition on the foundational reopening issue. The condition applies equally to reassessment following search where section 148A procedure is dispensed with. As the Revenue did not establish any addition based on material available at initiation, all additions arising from subsequent enquiries and verification were deleted. Both appeals were allowed, with remaining grounds left open.
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