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...
Reopening of assessment u/s 147 - Rejection of objections of the assessee - The stance of the Assessing Officer leads this Court to prima facie believe that the Assessing Officer had no good reason to issue the impugned notice for reopening. Had the Assessing Officer been more pro-active, he would have realized upon looking into the objections raised by the writ applicant that issuing notice for the assessment year 2015-16 could be a mistake. - AO directed to consider the objections raised by the assessee afresh - HC
Reopening of assessment u/s 147 - Rejection of objections of the assessee - The stance of the Assessing Officer leads this Court to prima facie believe that the Assessing Officer had no good reason to issue the impugned notice for reopening. Had the Assessing Officer been more pro-active, he would have realized upon looking into the objections raised by the writ applicant that issuing notice for the assessment year 2015-16 could be a mistake. - AO directed to consider the objections raised by the assessee afresh - HC
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