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 - time to initiate Revision u/s 263 was not left - Reopening is made at the direction of the ld. CIT. The ld. CIT when he did not find time to invoke provision of section 263 of the act, he directed ld. AO to initiate action u/s. 147 of the Act. Therefore, we do not find any reason to uphold the reopening of the assessment. - AT
Reopening of assessment u/s 147 - time to initiate Revision u/s 263 was not left - Reopening is made at the direction of the ld. CIT. The ld. CIT when he did not find time to invoke provision of section 263 of the act, he directed ld. AO to initiate action u/s. 147 of the Act. Therefore, we do not find any reason to uphold the reopening of the assessment. - AT
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