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...
Condonation of delay - sufficient cause - Request for Reopening of assessment order for accepting declarations in Form ‘C’ - power of authorities to reopen the proceedings after lapse of four years - no material particulars are placed on record with regard to the date of such closure - as no ‘sufficient cause’ has been made out by the petitioner to explain the delay in filing declarations in Form ‘C’, we are of the opinion no case for directing to reopen the assessment is made out. - HC
Condonation of delay - sufficient cause - Request for Reopening of assessment order for accepting declarations in Form ‘C’ - power of authorities to reopen the proceedings after lapse of four years - no material particulars are placed on record with regard to the date of such closure - as no ‘sufficient cause’ has been made out by the petitioner to explain the delay in filing declarations in Form ‘C’, we are of the opinion no case for directing to reopen the assessment is made out. - HC
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