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 - Sanction / Satisfaction of the proper authority u/s 151(1) - it prima facie appears that in view of the prescription of Section 151(1) by necessary implication, the "Additional Commissioner of Income Tax" would not be same as "Principal Chief Commissioner" or "Chief Commissioner" or "Principal Commissioner" or "Commissioner" of Income Tax. - the proceeding initiated against the petitioner company by issuance of notice u/s 148 is held to be not in accordance with law. - Quashed - HC
Validity of Reopening of assessment - Sanction / Satisfaction of the proper authority u/s 151(1) - it prima facie appears that in view of the prescription of Section 151(1) by necessary implication, the "Additional Commissioner of Income Tax" would not be same as "Principal Chief Commissioner" or "Chief Commissioner" or "Principal Commissioner" or "Commissioner" of Income Tax. - the proceeding initiated against the petitioner company by issuance of notice u/s 148 is held to be not in accordance with law. - Quashed - HC
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