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 - valid approval u/s 151 - “unsigned approval” issued in electronic form - The point of time when the AO issued notices u/s 148, he was having no jurisdiction to issue the impugned notices under section 148 of the Act, 1961. Consequently the impugned notices issued by the AO u/s 148 were without jurisdiction. The questions no. (a) and (b) are answered accordingly. - HC
Reopening of assessment u/s 147 - valid approval u/s 151 - “unsigned approval” issued in electronic form - The point of time when the AO issued notices u/s 148, he was having no jurisdiction to issue the impugned notices under section 148 of the Act, 1961. Consequently the impugned notices issued by the AO u/s 148 were without jurisdiction. The questions no. (a) and (b) are answered accordingly. - HC
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