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...
Reopening of assessment u/s 147 - If it is found by the Assessing Officer on such verification that the amount in question represents the sale proceeds of investments which were made by the assessee out of share capital and share premium amounting to ₹ 11.04 crores, which is already treated and accepted as income of the assessee by virtue of the settlement of dispute under Vivad Se Vishwas Scheme in A.Y. 2008-09, the same cannot be treated as income of the assessee again for the year under consideration as the same would amount to double addition. - AT
Reopening of assessment u/s 147 - If it is found by the Assessing Officer on such verification that the amount in question represents the sale proceeds of investments which were made by the assessee out of share capital and share premium amounting to ₹ 11.04 crores, which is already treated and accepted as income of the assessee by virtue of the settlement of dispute under Vivad Se Vishwas Scheme in A.Y. 2008-09, the same cannot be treated as income of the assessee again for the year under consideration as the same would amount to double addition. - AT
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