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...
Revision u/s 263 by CIT - Merely on the basis of audit objection powers u/s 263 could not have been exercised. The impugned order u/s 263, does not indicate that the power was exercised on the basis of a finding of the assessment order being erroneous and prejudicial to the Revenue by examining facts and record by the ld. Revisional Authority beyond the audit objections - AT
Revision u/s 263 by CIT - Merely on the basis of audit objection powers u/s 263 could not have been exercised. The impugned order u/s 263, does not indicate that the power was exercised on the basis of a finding of the assessment order being erroneous and prejudicial to the Revenue by examining facts and record by the ld. Revisional Authority beyond the audit objections - AT
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