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 - reasons to believe - “tangible material” - There is no whisper in the impugned reassessment order as to how the AO has arrived at the aforesaid amount as undisclosed income and that how the aforesaid amount represents undisclosed income of the petitioner/assessee. Thus the reassessment proceeding initiated by the AO against the petitioner for the AY 2017-18 was not only without jurisdiction but also it was abuse of power - HC
Reopening of assessment u/s 147 - reasons to believe - “tangible material” - There is no whisper in the impugned reassessment order as to how the AO has arrived at the aforesaid amount as undisclosed income and that how the aforesaid amount represents undisclosed income of the petitioner/assessee. Thus the reassessment proceeding initiated by the AO against the petitioner for the AY 2017-18 was not only without jurisdiction but also it was abuse of power - HC
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