Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Reopening of assessment u/s 147 - scope and effect of the Income Declaration Scheme (IDS) - to hold- as the High Court did, in this case, that since the assessee may have a reasonable explanation, is not a ground for quashing a notice u/s 147. As long as there is objective tangible material (in the form of documents, relevant to the issue) the sufficiency of that material cannot dictate the validity of the notice. - the High Court fell into error, in holding that the sequitur to a declaration under the IDS can lead to immunity (from taxation) in the hands of a non-declarant. - SC
Reopening of assessment u/s 147 - scope and effect of the Income Declaration Scheme (IDS) - to hold- as the High Court did, in this case, that since the assessee may have a reasonable explanation, is not a ground for quashing a notice u/s 147. As long as there is objective tangible material (in the form of documents, relevant to the issue) the sufficiency of that material cannot dictate the validity of the notice. - the High Court fell into error, in holding that the sequitur to a declaration under the IDS can lead to immunity (from taxation) in the hands of a non-declarant. - SC
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