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...
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
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