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 - the sole reason for completing the scrutiny assessment was suspicious LTCG earned by assessee based on information received from Investigation Wing, it could not be believed that A.O. would not have gone through the material available - non discussion the details in the assessment order would not give right to the Ld. Pr. CIT to hold that no investigation or enquiry was made - A.O. has taken one of permissible view - no revision
Revision u/s 263 - the sole reason for completing the scrutiny assessment was suspicious LTCG earned by assessee based on information received from Investigation Wing, it could not be believed that A.O. would not have gone through the material available - non discussion the details in the assessment order would not give right to the Ld. Pr. CIT to hold that no investigation or enquiry was made - A.O. has taken one of permissible view - no revision
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