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...
Reopening of assessment u/s 147 - eligibility of reasons to believe - the sole basis for the AO to form reasonable belief of escapement of income is, Tax Audit Report filed by the assessee along with return of income, which was very much available with the AO, when he had completed assessment proceedings u/s.143(3) of the Act. - notice issued by the AO u/s.148 of the Act, and consequent assessment proceedings u/s.147 of the Act, are bad in law - AT
Reopening of assessment u/s 147 - eligibility of reasons to believe - the sole basis for the AO to form reasonable belief of escapement of income is, Tax Audit Report filed by the assessee along with return of income, which was very much available with the AO, when he had completed assessment proceedings u/s.143(3) of the Act. - notice issued by the AO u/s.148 of the Act, and consequent assessment proceedings u/s.147 of the Act, are bad in law - AT
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