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...
Assessment u/s 153A - There is no specific provision in the Act requiring the assessment u/s 153A to be made after issuing notice u/s 143(2) - there is no legal impediment in making an addition, otherwise than on the basis of any incriminating material found during search, in an assessment u/s 153A for a year whose assessment was not pending on the date of search. - AT
Assessment u/s 153A - There is no specific provision in the Act requiring the assessment u/s 153A to be made after issuing notice u/s 143(2) - there is no legal impediment in making an addition, otherwise than on the basis of any incriminating material found during search, in an assessment u/s 153A for a year whose assessment was not pending on the date of search. - AT
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