International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Validity of reopening of assessment u/s 147 - assessment beyond a period of 4 years - mandation of recording satisfaction - The satisfaction as contemplated u/s 151 of the Act is not an empty formality as the authorities have to apply their mind and record satisfaction. When the authorities were not oblivious to the date of proposal then it cannot be said that they have applied their mind or considered the proposal of the AO in its right earnest. - AT
Validity of reopening of assessment u/s 147 - assessment beyond a period of 4 years - mandation of recording satisfaction - The satisfaction as contemplated u/s 151 of the Act is not an empty formality as the authorities have to apply their mind and record satisfaction. When the authorities were not oblivious to the date of proposal then it cannot be said that they have applied their mind or considered the proposal of the AO in its right earnest. - AT
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