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...
Reassessment notice u/s 148 - in pursuant to notice u/s 142(1), petitioner had furnished complete details with various documentary evidence and case was discussed by the ITO - It cannot be said that the tangible material which is said to have come to the notice of the AO was not taken into consideration and the income chargeable to tax have escaped assessment - reopening on the basis of the very same material, is change of opinion - notice quashed
Reassessment notice u/s 148 - in pursuant to notice u/s 142(1), petitioner had furnished complete details with various documentary evidence and case was discussed by the ITO - It cannot be said that the tangible material which is said to have come to the notice of the AO was not taken into consideration and the income chargeable to tax have escaped assessment - reopening on the basis of the very same material, is change of opinion - notice quashed
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