Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
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...
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Reassessment proceedings u/s. 147/148 - assessee company has not disclosed its income fully and truly - A perusal of the reasons recorded for reopening assessment shows that the entire exercise has been done by the Assessing Officer on the basis of assessment of GBN for AY 2007-08 wherein an amount on account of royalty paid to the assessee was found. The amount accrued by the payer in its books has no relevance as it is a trite law that payment may be treated differently in the books of payer and the payee. - AT
Reassessment proceedings u/s. 147/148 - assessee company has not disclosed its income fully and truly - A perusal of the reasons recorded for reopening assessment shows that the entire exercise has been done by the Assessing Officer on the basis of assessment of GBN for AY 2007-08 wherein an amount on account of royalty paid to the assessee was found. The amount accrued by the payer in its books has no relevance as it is a trite law that payment may be treated differently in the books of payer and the payee. - AT
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