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...
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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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