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...
Revision u/s 263 - PCIT is incorrect in coming to the conclusion that Assessing Officer has not examined the issue and applied his mind insofar as investments in fixed deposits - once the Assessing Officer has taken one of the two views permissible in law on which the PCIT does not agree and which resulted in loss of revenue, it cannot be treated as erroneous order prejudicial to the interests of the revenue, unless the view taken by the Assessing Officer is completely unsustainable in law. - AT
Revision u/s 263 - PCIT is incorrect in coming to the conclusion that Assessing Officer has not examined the issue and applied his mind insofar as investments in fixed deposits - once the Assessing Officer has taken one of the two views permissible in law on which the PCIT does not agree and which resulted in loss of revenue, it cannot be treated as erroneous order prejudicial to the interests of the revenue, unless the view taken by the Assessing Officer is completely unsustainable in law. - AT
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