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 reopening of assessment u/s 147 - notice issued to a company which is non-existent on the date as it stood amalgamated with the appellant/petitioner - ts conduct of filing return of income in the name of OAS after the amalgamation and obtained refunds issued in the name of OAS, which will all go to show that M/s.OAS continued to exist even after amalgamation. - Therefore, appellant cannot canvass the point that OAS was nonexistent and the proceedings initiated in its name would be bad in law. - HC
Validity of reopening of assessment u/s 147 - notice issued to a company which is non-existent on the date as it stood amalgamated with the appellant/petitioner - ts conduct of filing return of income in the name of OAS after the amalgamation and obtained refunds issued in the name of OAS, which will all go to show that M/s.OAS continued to exist even after amalgamation. - Therefore, appellant cannot canvass the point that OAS was nonexistent and the proceedings initiated in its name would be bad in law. - HC
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