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...
Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.
Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.
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