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...
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Revision u/s 263 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. - AT
Revision u/s 263 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. - AT
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