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 - Writ jurisdiction of this Court under Article 226 of the Constitution of India or supervisory jurisdiction of this Court under Article 227 of the Constitution of India cannot be invoked to attack the sufficiency of the reasons assigned for re-opening of a case of escaped income so long as the power exercised and the reasons assigned therefore are traceable to any statutory provision. Thus, it cannot be said that the impugned notice of the assessment and re-opening of the case u/s 147 of the IT Act is bereft of jurisdiction. - HC
Reopening of assessment u/s 147 - Writ jurisdiction of this Court under Article 226 of the Constitution of India or supervisory jurisdiction of this Court under Article 227 of the Constitution of India cannot be invoked to attack the sufficiency of the reasons assigned for re-opening of a case of escaped income so long as the power exercised and the reasons assigned therefore are traceable to any statutory provision. Thus, it cannot be said that the impugned notice of the assessment and re-opening of the case u/s 147 of the IT Act is bereft of jurisdiction. - HC
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