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 - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
Validity of Reopening of assessment - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
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