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...
Enhancement of income - Exercise of power by the CIT(A) u/s 251 - introducing new source of income - It is not open for the ld. CIT(A) to travel outside the assessment order with a view to find out new sources of income. There must be something in the assessment order to show that Ld. AO had applied his mind to the particular subject matter with a view to its taxability or its nontaxability and not to any incidental connection. - order of the CIT (A) set aside - Additions deleted - AT
Enhancement of income - Exercise of power by the CIT(A) u/s 251 - introducing new source of income - It is not open for the ld. CIT(A) to travel outside the assessment order with a view to find out new sources of income. There must be something in the assessment order to show that Ld. AO had applied his mind to the particular subject matter with a view to its taxability or its nontaxability and not to any incidental connection. - order of the CIT (A) set aside - Additions deleted - AT
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