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 the ld. PCIT - Neither the AO had enquired into the sources of cash deposits nor the appellant had offered any explanation in support of the sources for cash deposits. This clearly goes to prove the AO had failed to examine this issue during the course of original assessment proceedings, which rendered the assessment order erroneous and prejudicial to the interests of the Revenue. - AT
Revision u/s 263 by the ld. PCIT - Neither the AO had enquired into the sources of cash deposits nor the appellant had offered any explanation in support of the sources for cash deposits. This clearly goes to prove the AO had failed to examine this issue during the course of original assessment proceedings, which rendered the assessment order erroneous and prejudicial to the interests of the Revenue. - AT
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