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...
Validity of reopening of assessment - In the impugned order, the Assessing Officer (AO) seems to have completely gone off the rails i.e., in a completely different direction, by adverting to the fact that petitioner/assessee entered into two sale transactions concerning penny stock scrips of Prikh Herbals Ltd./Safal Herbs Ltd. - Clearly, there is a dissonance between the show cause notice issued under Section 148A(b) and the impugned order passed under Section 148A(d) of the Act. Thus the impugned order and notices are set aside. - HC
Validity of reopening of assessment - In the impugned order, the Assessing Officer (AO) seems to have completely gone off the rails i.e., in a completely different direction, by adverting to the fact that petitioner/assessee entered into two sale transactions concerning penny stock scrips of Prikh Herbals Ltd./Safal Herbs Ltd. - Clearly, there is a dissonance between the show cause notice issued under Section 148A(b) and the impugned order passed under Section 148A(d) of the Act. Thus the impugned order and notices are set aside. - HC
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