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...
Validity of Proceeding u/s 158BC - satisfaction was not recorded before completion of assessment proceeding - the order passed by the AO as well as the CIT (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Apex Court.
Validity of Proceeding u/s 158BC - satisfaction was not recorded before completion of assessment proceeding - the order passed by the AO as well as the CIT (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Apex Court.
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