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...
Reassessment against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.
Reassessment against a dissolved partnership firm after its business succession is void where the Department had accepted that the firm ceased to exist and the successor proprietor disclosed and was assessed on the same business transactions and bank accounts. Assessing the erstwhile firm in these circumstances would duplicate taxation of the same business income. Jurisdiction for reassessment also requires recorded reasons identifying the relevant bank account or transaction and foundational material showing income escaped assessment; vague reasons do not meet that standard. A notice issued to a non-existent entity after succession renders the consequential assessment and estimated addition unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
