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...
Withdrawal of exemption as provided u/s. 12A - Revenue could not controvert the fact that the sole ground of re-opening of assessment was that the Registration granted u/s. 12A of the Act had been cancelled since inception, therefore, the assessee was not eligible for the benefit of sections 11 & 12 of the Act. Under the undisputed fact that the basis of reopening of the assessment now no more exists - assessment framed on the basis of such ground cannot be sustained. - AT
Withdrawal of exemption as provided u/s. 12A - Revenue could not controvert the fact that the sole ground of re-opening of assessment was that the Registration granted u/s. 12A of the Act had been cancelled since inception, therefore, the assessee was not eligible for the benefit of sections 11 & 12 of the Act. Under the undisputed fact that the basis of reopening of the assessment now no more exists - assessment framed on the basis of such ground cannot be sustained. - AT
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