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 - the issue was duly considered by Ld. AO after considering assessee’s detailed submissions. The view could not be said to be unsustainable view and it was one of the possible view - we find that the subject matter of proposed revision was already deliberated upon by Ld. AO and a possible was taken in the matter - assessment order could not be subjected to revision u/s 263 - AT
Revision u/s 263 - the issue was duly considered by Ld. AO after considering assessee’s detailed submissions. The view could not be said to be unsustainable view and it was one of the possible view - we find that the subject matter of proposed revision was already deliberated upon by Ld. AO and a possible was taken in the matter - assessment order could not be subjected to revision u/s 263 - AT
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