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...
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Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
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