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...
Stay petition - prima facie case - on objections being filed by the assessee, the AO disposed of the objections then in appeal the CIT(A) ought to have considered the validity of the reopening and not rejected the appeal on the ground that the assessee participated in response to the notice issued u/s 148 - this would be sufficient to hold that the assessee has made out a prima facie case
Stay petition - prima facie case - on objections being filed by the assessee, the AO disposed of the objections then in appeal the CIT(A) ought to have considered the validity of the reopening and not rejected the appeal on the ground that the assessee participated in response to the notice issued u/s 148 - this would be sufficient to hold that the assessee has made out a prima facie case
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