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...
Assessment u/s 153A - Authorisation and assessment in case of search or requisition - Constitutional validity of Section 292CC - As however a fact that the CIT(A) and ITAT cannot consider the “reason to believe” or “reason to suspect” on merit, but was only for limited purpose. In view of the above, even if the explanations to the provisions referred to above have been added by the Finance Act, 2017, it cannot be said to be offending Articles 14, 19 or 21 of the Constitution of India and otherwise retrospectivity of the amendment is permissible unless it remains otherwise unconstitutional. Thus, we summarily reject the challenge to the addition of Explanations to Sections 132(1), 132(1A) and 132A(1) of the Act of 1961 by the Finance Act of 2017 and hold it to be constitutionally valid. - HC
Assessment u/s 153A - Authorisation and assessment in case of search or requisition - Constitutional validity of Section 292CC - As however a fact that the CIT(A) and ITAT cannot consider the “reason to believe” or “reason to suspect” on merit, but was only for limited purpose. In view of the above, even if the explanations to the provisions referred to above have been added by the Finance Act, 2017, it cannot be said to be offending Articles 14, 19 or 21 of the Constitution of India and otherwise retrospectivity of the amendment is permissible unless it remains otherwise unconstitutional. Thus, we summarily reject the challenge to the addition of Explanations to Sections 132(1), 132(1A) and 132A(1) of the Act of 1961 by the Finance Act of 2017 and hold it to be constitutionally valid. - HC
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