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 - AO recorded in order that assessee had “duly furnished the details of opening stock, closing stock, sales and production i.e. consumption of paddy etc.” this was a case of ‘no inquiry’ - CIT has not undertaken any independent inquiry to contradict the conclusions reached by the AO and to demonstrate that the order of the AO was erroneous and prejudicial to the interest of the revenue - revision not sustainable
Revision u/s 263 - AO recorded in order that assessee had “duly furnished the details of opening stock, closing stock, sales and production i.e. consumption of paddy etc.” this was a case of ‘no inquiry’ - CIT has not undertaken any independent inquiry to contradict the conclusions reached by the AO and to demonstrate that the order of the AO was erroneous and prejudicial to the interest of the revenue - revision not sustainable
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