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 - Addition u/s 68 r.w.s 115BE - Nothing stated in the pre-amended or post amended provisions of section 115BBE that where the assessee surrenders undisclosed income during search action for the relevant year, the tax rate has to be charged as per provisions of section 115BBE - the applicability of the amended provisions which prompted the PCIT to assume jurisdiction under section 263 is highly debatable issue - Revision order quashed - AT
Revision u/s 263 by CIT - Addition u/s 68 r.w.s 115BE - Nothing stated in the pre-amended or post amended provisions of section 115BBE that where the assessee surrenders undisclosed income during search action for the relevant year, the tax rate has to be charged as per provisions of section 115BBE - the applicability of the amended provisions which prompted the PCIT to assume jurisdiction under section 263 is highly debatable issue - Revision order quashed - AT
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