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 - failure to provide the copy of recording of "reason to believe" to the assessee - copy of reasons recorded has to be provided to assessee before completion of assessment order. We find that CIT(A) has rightly accepted the contention of the assessee and after relying on number of case laws, decided the issue in favour of the assessee. - AT
Reopening of assessment u/s 147 - failure to provide the copy of recording of "reason to believe" to the assessee - copy of reasons recorded has to be provided to assessee before completion of assessment order. We find that CIT(A) has rightly accepted the contention of the assessee and after relying on number of case laws, decided the issue in favour of the assessee. - AT
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