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 - under-reporting of capital gains - where the relevant facts have been overlooked and has not taken cognizance of, resulting in escapement of chargeable income, such omission would not constitute ‘change of opinion’. In the absence of any other contention, we do not see any merit in the plea of assessee towards wrongful usurpation of jurisdiction u/s 147 - AT
Validity of reopening of assessment u/s 147 - under-reporting of capital gains - where the relevant facts have been overlooked and has not taken cognizance of, resulting in escapement of chargeable income, such omission would not constitute ‘change of opinion’. In the absence of any other contention, we do not see any merit in the plea of assessee towards wrongful usurpation of jurisdiction u/s 147 - AT
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