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...
Revision u/s 263 - Issue considered and decided in appeal by appellate authorities, such matters cannot be subject to revision u/s 263. Rationale behind exclusion of such orders from purview of section 263 is that, if CIT (A) decides issue against revenue, revenue has right to challenge it before higher appellate forum.
Revision u/s 263 - Issue considered and decided in appeal by appellate authorities, such matters cannot be subject to revision u/s 263. Rationale behind exclusion of such orders from purview of section 263 is that, if CIT (A) decides issue against revenue, revenue has right to challenge it before higher appellate forum.
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