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...
Conversion of limited scrutiny into complete scrutiny assessment - AO has not referred to any credible or reliable material or information to form the view that there was a possibility of under assessment of income in this case. The AO has merely made certain disallowance on ad hoc basis without pointing out any information or material available to him which has a direct nexus to show that there was possibility of under assessment of income. - Conversion of limited scrutiny into complete scrutiny is against the spirit of CBDT mandate which is binding on the AO. - AT
Conversion of limited scrutiny into complete scrutiny assessment - AO has not referred to any credible or reliable material or information to form the view that there was a possibility of under assessment of income in this case. The AO has merely made certain disallowance on ad hoc basis without pointing out any information or material available to him which has a direct nexus to show that there was possibility of under assessment of income. - Conversion of limited scrutiny into complete scrutiny is against the spirit of CBDT mandate which is binding on the AO. - AT
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